The FCA has published an alert setting out considerations for Principals who have Appointed Representatives (ARs) or Introducer Appointed Representatives.

The FCA expects Principals to review and consider:

• the introducer relationships that they and their ARs have to determine if the firm is under undue influence;
• their AR relationship to ensure they remain necessary, appropriate and relevant for their type of business;
• their processes relating to persons with significant control and senior management responsibilities or functions within their ARs;
• whether their due diligence and monitoring processes are adequate;
• whether they need to take any additional steps to ensure the actions of their ARs are compatible with their obligations as an AR, and allow the Principal to meet its regulatory responsibilities; and
• the alert that the FCA issues on 2 August 2016 entitled Investment advisers’ and authorised firms’ responsibilities when accepting business from unauthorised introducers or lead generators.

The FCA is continuing its work in this area and will take action where it identifies non-compliance with its requirements. The FCA expects Principals to consider the FCA’s alert and take appropriate action.

View FCA alert for firms with appointed representatives, 3 November 2017