The FCA has published an alert to all Principals, regardless of sector, who have one or more Appointed Representatives or Introducer Appointed Representatives (‘ARs’). Principals are responsible for the regulated activities of their ARs. The alert sets out the risks that the FCA expects firms to consider and act upon, where relevant.
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This is a follow up to previous alerts about the risks involved in dealing with Introcuders. All Principal and Appointed Representative firms should read it.
For information.
A temporary solution if there are problems obtaining an LEI in time for any affected transactions from 3 January 2018.
There are some apparent anomalies in the rules. We have obtained ‘clarification’ from the FCA.
The FCA has clarified some aspects of how the recording rules will apply to firms that are not Article 3 Exempt.
How will changes to compliance governance affect your company?
MiFID II – Aggregated costs disclosure
Alistair MacDougall Compliance 2017, 2018, 2019, MiFID, PI
This new requirement is posing some questions about how it can best be implemented. We think that firms should wait until the mechanisms in the market place are a little clearer.