Link(s): | Principal firms who have Credit Broking permissions: Good practice and areas for improvements | FCA |
Context
The FCA has assessed the key harms and drivers of harm caused by Appointed Representatives (ARs) and Introducer Appointed Representatives (IARs) who undertake credit broking. It wants to improve principals’ oversight of their ARs and has offered examples of good practices as well as areas for improvement it has seen in principal firms’ due diligence checks and ongoing monitoring of ARs.
Key points to note and next actions
The publication of the FCA’s ‘Principal firms who have Credit Broking permissions: Good practice and areas for improvements’ builds on its policy statement and work to improve the AR regime. The guidance the FCA’s examples refer to can be found in SUP 12: Application and purpose.
The guidance covers:
- The initial appointment of ARs and IARs
- Ongoing monitoring of ARs and IARs
- Ending AR and IAR relationships
The FCA has highlighted that it will act where it identifies firms that do not have adequate oversight of their ARs. Therefore, all principal firms who have ARs should consider the FCA’s findings and guidance, addressing any gaps in respect of their initial and ongoing monitoring of ARs.