Appointed Representative Oversight.pdf
If you’re a Principal firm, your Appointed Representatives are your regulatory responsibility — and the FCA now expects you to prove it.
Since the FCA’s enhanced AR regime took effect (PS22/11, December 2022), Principals must actively oversee, monitor and evidence the conduct of every AR as if their own permissions depended on it — because they do. Weak oversight is one of the most common reasons Principals face supervisory intervention, s.166 reviews, or the forced termination of AR relationships. Many firms simply don’t have a defensible oversight framework written down.
What’s inside
✔ A plain-English explanation of your obligations as a Principal under SUP 12 and the enhanced AR rules
✔ The self-assessment questions the FCA expects you to be able to answer about each AR
✔ A practical oversight framework covering onboarding due diligence, ongoing monitoring, and annual review
✔ The red flags that signal an AR relationship has become a regulatory liability
✔ Record-keeping expectations that stand up to supervisory scrutiny
Who it’s for
Principal firms with one or more Appointed Representatives or Introducer ARs — across investment, mortgage, insurance and consumer credit sectors.
The benefit to you
You’ll move from hoping your oversight is adequate to knowing it is — with a documented, defensible framework that protects your permissions and your reputation.
Key sources: FCA PS22/11 ‘Improving the Appointed Representatives regime’; SUP 12 (Appointed Representatives); the FCA’s AR data collection requirements.
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