Becoming an Appointed Representative (AR) is just a case of filling in a form and sending it to the FCA isn’t it?
There is a form to complete, yes, but there’s a lot more to becoming an AR than that.
Oh, so what else is there?
Well, we need to undertake due diligence on you, your business and the systems that you have in place.
There’s nothing on the FCA website about that, why do you need to do it?
The FCA do not set out exactly what they require to be done, instead they advocate a risk-based approach. If you become our AR, as your principal we are ultimately accountable to the FCA for ensuring that you will be able to comply with the regulatory requirements.
But that’s just a case of ticking boxes surely?
There are boxes to be ticked but in themselves they aren’t important. Before we submit your application we need to ensure that your business is financially stable, that you & your staff are financially competent and that you have systems in place to ensure that your customers are treated fairly.
So what sort of things might you need from us?
We’ll need your latest accounts and business plan with financial projections for the next 3 years. For you and key members of staff: résumés, certified anti-money laundering ID and criminal record checks. And we’ll want to review the documented processes that you have in place for accepting investors & investees.
OK, so there’s more to becoming an AR than just completing a form but after that we can just get on with things?
Becoming an AR means that you can run regulated activities and we’re here to make sure that you can do that compliantly. But our responsibility to the FCA goes beyond the initial application process. Ongoing we need to ensure that you comply with FCA regulations and continue to treat customers fairly.
You keep going on about treating customers fairly.
There’s a reason for that. First, without customers your business will fail and treating them fairly will likely mean that they come back & recommend you to others. Secondly, every aspect of FCA regulation comes back to safeguarding consumers.
That makes sense. So what do you do after we become your AR?
We establish a regular monitoring programme to ensure that you continue to operate within the regulatory framework and that you maintain records to demonstrate that is the case.
That sounds like an audit?
It does and that’s why we have people at ShareIn with Big 4 financial services audit experience to help you.