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.
Advising non-UK clients
Alistair MacDougall Compliance Conduct, EEA, email, EU, FCA, MiFID, passport, PI, vulnerable
Despite the fact that the UK ceased to be a member of the EU/EEA almost a year ago, we are still asked for advice around how a UK firm can take on a new non-UK client or continue to deal with such clients that the firm had pre-BREXIT. We have written before about the general […]