The FCA has issued the following reminders for Principal Firms.
Respond to our request for information about Appointed Representatives (ARs)
In December 2022 we sent a mandatory Section 165 (S165) request to principal firms. This request reflects new rules requiring principals to provide more information about their Appointed Representatives (ARs) and strengthens the responsibilities and expectations of principals.
Principal firms with ARs must respond to this request by 28 February 2023.
We have provided S165 guidance for principal firms to help you complete the request.
Reminder: notify us of any changes in status to your Appointed Representatives
Our analysis of Companies House data shows that some Principal firms fail to tell us when their Appointed Representatives (ARs) enter administration, liquidation or dissolution.
You must notify us immediately if there is a change in status to any ARs you oversee, including where they:
- go out of business – using a ‘Terminate AR’ form
- change name – using a ‘Change AR’ form
We also remind you of new rules that clarify and strengthen the responsibilities and expectations of Principals. Further information can be found in SUP 12.3 of the FCA Handbook and on the website.



Abridged advice – how is it going so far?
Alistair MacDougall Compliance 2015, 2018, 2020, 2021, abridged, Drawdown, FCA, Pension, Pension Transfer, PI, transfer
Based on data and live visits to firms during the period from April 2015 to rule changes in 2018 and 2020, the FCA believed that far too high a proportion of clients were being recommended to transfer safeguarded benefits. This was predicated on the longstanding rule which stated: “… a firm should start by assuming […]