If your firm is part of a network

If your firm is an appointed representative of a network, check four things before introducing a client to an adviser outside it. The network agreement usually answers all of them.

4 min read · Guide for brokers

1

Why this is the first question

An appointed representative carries on regulated activities under its principal's permissions. It does not hold its own. That is why the principal has a say in what the firm does.

Network agreements usually say something about where business outside the firm's own permissions can go. Some allow introductions to any authorised adviser. Some require introductions to go to a panel. Some require the network's own wealth arm to be offered first. The position is written in the agreement.

2

Four things to check in the agreement

Whether introductions outside the network are permitted at all

, and for which kinds of business.

Whether there is a panel

of approved firms, and how a firm gets added to it.

Whether any payment for an introduction must be declared

to the network, or passes through it.

Whether the network needs to approve the arrangement

before the first introduction is made.

If the agreement is silent or unclear on any of these, ask the network in writing. Get the answer in writing.

3

Directly authorised firms

A firm authorised in its own right has no principal to consult, and decides its own introducer arrangements. It still carries its own obligations: managing any conflict of interest, and treating the client fairly under the Consumer Duty.

In practice that means being clear with the client about the arrangement and about the fact that the adviser is a separate firm.

4

What to say to your network

Send a short, clear request:

Wording you can use“We would like to introduce clients who need pension, investment or estate planning advice to Equity & General Financial Services, FCA number 474163, under an introducer arrangement. Can you confirm whether our agreement permits this, whether any approval is needed, and whether anything must be declared to you?”

Keep the reply on file. It is the evidence that the arrangement was checked before it started.

5

If the answer is no

Some networks will only allow introductions to their own wealth business or panel. That is the network's decision.

If it applies to your firm, find out before a client conversation. It may also be a factor the next time the network arrangement comes up for review.

Related reading

Talk to us about a Pecunia partnership

Your firm keeps the mortgage and protection advice. Equity & General gives the pension, investment and estate planning advice, and a named partnership manager sets the arrangement up with you.