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.
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.