Context
The FCA has asked us to remind our members that the S165 data collection on Appointed Representatives must be completed before 28th February 2023. Failure to complete the request could lead to enforcement action.
Key points to note
The FCA will be issuing a schedule of reminders during January and February, to firms that are yet to submit. Firms’ progress is also being monitored with the data collection.
Initial analysis of the data received by the FCA shows some of the most common errors when submitting the data include:
- Firms failing to submit details for all of their ARs and
- Firms submitting the wrong FRN for their ARs:
- Submitting their own FRN as that of the AR
- Noting the FRN of a different AR in the submission
- Using an old FRN of an AR (for example if the AR used to be directly authorised and then became an AR, and acquired a new FRN in the process)
Firms can double check their AR population details against the Financial Services Register.
The removal of these errors will mean the data is more accurate and the FCA will not have to contact firms for the correct data.
Next actions
If your firm has any Appointed Representatives or Introducer Appointed Representatives registered, ensure you complete the S165 request before the deadline.