Compliance Monitor
Appointed Representatives are TCF weakpoint
Four firms may be referred to Enforcement and another 11 face follow-up visits after the FSA found flaws in their oversight
of appointed representatives. The recent review looked at 35 smaller intermediary Principals and 67 of their ARs, from the
mortgage, general insurance and investment sectors and covered 12 firms first seen in 2006. The regulator came across departures
from written procedures, undue emphasis on remote checking of client files as the only means of monitoring ARs, delays in
work on Treating Customers Fairly and weak communication with ARs. TCF project work was hindered, says the FSA, by an absence
of relevant management information and the means to test if ARs were working on the same outcomes. The worst shortcomings
were evident in general insurance firms, the mortgage sector fared better and investment firms were performing best. “It is
disappointing that failings still persist despite the help and information available from the FSA,” said Stephen Bland, Director,
Small Firms Division. All firms and their ARs must be able to demonstrate that they are treating customers fairly by the end
of December 2008, he added.