On 1 September 2023, the FCA published Consultation Paper 23/18 ‘Quarterly Consultation No. 41’ (CP23/18).

Among other things in CP23/18 the FCA is proposing to amend Supervision Manual (SUP) 12.4.10AR to clarify that it is the principal firm that must obtain and maintain continuous professional indemnity insurance (PII) cover for the activities for which it may be liable because of the conduct of its appointed representatives. The FCA believes that most principal firms are holding PII policies that extend to the activities of their appointed representatives in line with the Prudential sourcebook for Mortgage and Home Finance Firms, and Insurance Intermediaries (MIPRU). Principal firms that are subject to SUP 12.4.10AR and MIPRU 3 should check their policies to ensure that the activities for which they may be liable because of the conduct of their current and former appointed representatives are covered and make amendments where necessary. 

The deadline for responding to CP23/18 is 9 October 2023.