ICS were tasked with reviewing a brokers’ network of Introducer Appointed Representatives (IARs), primarily to ensure that they were not exceeding the limited role that an IAR can perform.
Initially this involved mapping all of the sources of business and creating a register detailing the relevant personnel within the introducer and their counterpart within the Principal firm.
The task was completed by interviewing key staff within the introducer firm and also performing a detailed review of the following:
- The introducer agreements in place
- The websites of the introducers
- Marketing activity of the introducers
ICS reviewed activity against the actual agreements in place and the allowable activities of an IAR. During the process we found examples of agreements being outdated or unsigned. It was common to find that the correct regulatory disclosures were missing from marketing material and there were instances of IAR’s inadvertently going beyond their regulatory permissions. In 2022 FCA will be putting a lot of focus on to the Appointed Representative regime, and it is clearly important that where such arrangements exist the Principal firm must have excellent monitoring and oversight of all of its sources of business.