APPOINTED REPRESENTATIVE OVERSIGHT POLICY & PLAYBOOK

The FCA's October 2024 review of 270 principal firms found widespread failures in AR oversight. Only 52% of self-assessments were good quality. Just 43% of annual reviews met expectations. Fewer than a third of principals even reviewed their ARs' consumer-facing materials.

If you are a principal firm with Appointed Representatives, the FCA is watching — and it expects far more than a tick-box approach.

This comprehensive policy and playbook gives you a complete, deployable AR oversight framework built around the FCA's enhanced rules (PS22/11) and its latest good practice findings.

WHAT IS INCLUDED:

15 Core Policy Sections:

• Purpose, scope, and regulatory framework (FSMA, SUP 12, PS22/11)
• Governance and SMCR accountability mapping
• Pre-appointment due diligence procedures
• AR agreement requirements (SUP 12.5)
• Ongoing monitoring and oversight framework
• Annual review procedures (SUP 12.6A)
• Self-assessment framework
• Consumer Duty integration for AR oversight
• Financial crime controls for AR activities
• Introducer Appointed Representative (IAR) specific requirements
• Overseas Appointed Representative (OAR) guidance
• Termination and orderly wind-down procedures
• Record-keeping and FCA data submission requirements
• Professional indemnity insurance (PII) oversight
• AR risk assessment methodology with risk-based monitoring intensity

6 Ready-To-Use Templates (Appendices):

• Appendix A: Pre-Appointment Due Diligence Checklist (20 items)
• Appendix B: Annual Review Template (fitness and propriety, financial position, controls adequacy)
• Appendix C: Self-Assessment Template (13) valuation areas with RAG ratings)
• Appendix D: Site Visit Report Template (10 observation areas)
• Appendix E: MI Dashboard Template (13 monthly monitoring metrics)
• Appendix F: Termination Checklist (16-step orderly wind-down process)

WHO IS THIS FOR:

• Principal firms with existing AR networks seeking to strengthen oversight
• Firms appointing ARs for the first time
• Compliance Officers and AR Oversight Managers
• Senior Managers (SMF16/17) with personal accountability for AR oversight
• Firms preparing for FCA supervisory visits or section 166 reviews
• Networks, regulatory hosts, and firms with IARs

REGULATORY ALIGNMENT:

• FCA Handbook SUP 12 (Appointed Representatives)
• PS22/11 (Enhanced AR Oversight Rules, December 2022)
• FCA October 2024 Good Practice and Areas for Improvement
• Consumer Duty (PS22/9 and FG22/5)
• SMCR accountability framework
• SYSC 9 record-keeping requirements
• MIPRU 3.2 (PII requirements)
• MLRs 2017 (financial crime)
• FCA OAR guidance (updated May 2025)

FORMAT: Fully editable Microsoft Word document (.docx) with professional formatting, branded tables, and version control. Customise with your firm's details and deploy immediately.

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