Reminder for firms: Appointed Representatives (ARs) – Data Request

On 9th August 2022 we wrote regarding the changes coming to the Appointed Representative Regime specifically outlining the new rules for Principal firms, the two main areas of change and the outcome the FCA are looking for.  The new rules will take effect on 8 December 2022.

One of the two mains areas of change as detailed in the policy statement PS22/11 is the collecting of additional information on ARs and strengthening requirements for Principal firms. A summary of the final rules and notification requirements can be found in section 2.81 of the policy statement.

As part of improved reporting requirements, the FCA will be sending Principal firms a Section 165 data request in December.

Firms will have 60 days to respond and provide the following information about its ARs:

  • reasons for any appointments
  • nature of regulated business
  • whether they conduct any unregulated business
  • anticipated revenue
  • nature of financial arrangements between principal and AR
  • complaints information and whether the AR is part of a group.

Important Note: ATEB news is intended to provide general information ONLY. The content, including any views expressed or guidance provided, does not replace the need to comply fully with FCA Rules and Guidance. Unless you have discussed news article content with ATEB, and specifically how it relates to your circumstances, then ATEB disclaims all liability and responsibility and actions arising from any reliance placed upon it. For the avoidance of doubt therefore, any reliance you place on such information without our consultation is at your own risk.

ATEB Compliance offers compliance and regulatory advice.

ATEB Suitability provides report writing software for the financial services market.

Our View

Principal firms should ensure that AR Monitoring Assessments are up to date, records/MI are robust and that they are able to respond to the request for data.

Action Required By You

If you are a Principal firm with ARs we recommend that you undertake a gap analysis of the data you hold on your ARs to ensure that you can meet the FCA deadline with a robust response.
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About the Author

Lisa has a wide range of skills and knowledge, and a track record of implementing compliance and T&C systems and processes of the highest calibre, covering all aspects of financial services.

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