Its not Us, its THEM!

 

During our time as a growing Appointed Representative Network, we constantly have the same conversation with existing Appointed Representatives. It goes something like this;

“We are fine, we operate properly and have been with this Principal for many years! We place lots of business and its works well! I wouldn’t want to change at this time”

To which I often answer with a selection of :

” That great, so may I ask what Compliance Monitoring does your Principal give? When did they last check your Solvency or Liquidity? What training package do they provide? Do they have a CASS report?”

This is often met with either silence or an answer that avoids the questions….

The reality of this situation is this. If your Principal is not working with you on these matters, they are not effectively supervising you. This means that they are in breach of the FCA’s rules. If we refer back to the FCA’s Thematic Review of Appointed Representative in 2016, one of the most damning things in the report was the Principals were failing to adequate supervise their Appointed Representatives.

The fact is this, an Appointed Representative could perform the best compliance on themselves but if the Principal is not performing their required tasks, everybody is at risk!

 

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