New attestation requirement for Principal Firms regarding the details of their Appointed Representatives
The FCA recently introduced a new requirement for Principal Firms to confirm (and amend, if necessary) the details of their Appointed Representatives (“AR”) and Introducer Appointed Representatives (“IAR”) on an annual basis. The new requirement will apply to all Accounting Reference Dates (“ARD”) from 1 December 2023.
The FCA has also taken the opportunity to update its reporting webpage for Principal Firms, reminding them of the 3 main sets of reporting data that will now apply in respect of their ARs:
- Complaints and revenue: Principal Firms must report this data annually using the REP025 form within 60 business days of their ARD. FAQs are available for this data set.
- Firm Details Attestation: Principal Firms are already required to attest (and amend, if necessary) their details annually using Connect. From 1 December 2023, they must also confirm details for their ARs and IARs, within 60 business days of the ARD. The attestation is made by logging in to Connect, selecting 'start new application', then 'update or attest to your firm details'.
- New Appointed Representatives: Principal Firms are required to notify the FCA when they take on a new AR, at least 30 calendar days before the appointment starts. They must also notify any changes to the AR’s activities at least 10 days before these take effect.
This new attestation is not onerous in its own right, but can be seen as part of the FCA’s increased its scrutiny of Principal Firms. In recent years, the AR Regime has been identified as a potential weak spot in its defence of the regulatory perimeter and protection of consumers. It comes after new take-on and ongoing monitoring requirements came into force in December 2022, following the publication of PS22/11: Improvements to the Appointed Representative Regime. The FCA has also reminded Principal Firms that they may be contacted for ad hoc data requests, as indeed they were with a section 165 request last December.
Cosegic is available to assist Principal Firms with any of the above requirements. If you have any questions or require support with attesting your AR details, please get in contact with us.
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