The questions a broker's compliance function, network or PI insurer raises about a wealth partnership, with the answers: the introducer agreement, where the regulated liability sits, what data moves and when, and how you stay inside your permissions.
Before you take on a wealth partnership, someone will want to check it. Your compliance function, your network if you are an appointed representative, or your professional indemnity insurer will have questions about what you are agreeing to. The arrangement is designed to be checked.
The partnership keeps you inside your existing permissions and keeps the regulated advice, and its liability, with E&G. The questions below are the ones a compliance team, network or PI insurer usually raises.
The firm needs no permission it does not already hold. You advise on mortgages and protection under the permissions your firm has now. The regulated advice on pensions, investments and estate planning is given by E&G, which is authorised and regulated by the FCA under firm reference number 474163. You are introducing clients to an authorised firm, and that does not require you to vary your permissions.
The regulated advice is E&G's. They assess the client, make the recommendation, document its suitability and hold the professional indemnity cover for that advice. If a pension or investment recommendation is ever challenged, it is E&G's recommendation, E&G's file and E&G's responsibility.
Your exposure is limited to having made a sensible introduction and recorded the client's consent. You are not answerable for advice you did not give. Put that in front of your PI insurer early.
Compliance will want to be certain the firm introduces and does not give regulated advice. Naming a need is introducing. Telling the client what to do about it is advising.
Your staff need to understand that line, and it is reasonable for compliance to ask how they are briefed on it. Nobody in the firm should recommend a course of action on a pension, an investment or an estate. They identify the need and introduce.
There is a written introducer agreement between your firm and E&G, and compliance will want to read it. It sets out the arrangement in writing.
The agreement records who the parties are, that E&G is FCA-authorised and provides the regulated advice, that your firm introduces clients within its own permissions, how client consent and data are handled, and how you are remunerated. It also makes clear that the arrangement is not a guarantee of income and that commercial terms are agreed individually. Your compliance team can review it against your own policies before anything goes live.
Little client data moves, and only with consent. At the point of introduction, once the client has agreed, you pass E&G the client's contact details and the nature of the need you have identified. Nothing is shared before the client consents, and the client is told the introduction is being made.
The lawful basis for the transfer is the client's consent, recorded at the point of introduction. Each firm is responsible as data controller for its own handling of the client's information. Your compliance team will want the consent wording and the record-keeping to be clean, and both can be evidenced through the partner portal or your own notes.
Compliance will check that the way you talk to clients does not stray into promoting regulated products. Your part is to say that you work with an FCA-authorised financial planning firm and can introduce the client. That is an introduction and recommends no product.
Any regulated communication about the advice or the products belongs to E&G, who are authorised to make it and responsible for it. Keeping your own statements to identifying a need and offering an introduction keeps you clear of giving or promoting regulated advice.
You are paid for the introduction and, under the partner model, for a share in the ongoing value of the assets E&G manages for clients you introduce. It is disclosed to the client in writing.
On conflicts, the client's advice must be suitable and in their interest regardless of any arrangement with you, and E&G's regulated obligations require that. The client pays E&G for the advice on the same basis whether or not you share in it, so your involvement adds nothing to the client's cost and does not affect the advice. The arrangement is disclosed to the client so they understand your role.
Because the advice is E&G's, complaints about the advice go to E&G. They handle them under their own FCA complaints obligations, with the Financial Ombudsman Service available to the client in the usual way. The suitability of the recommendation, and any redress if it was wrong, sit with the firm that gave it.
Your responsibility runs to the quality of the introduction and the consent behind it. A clean record of both protects your firm if a client ever questions how they came to be advised.
If you are an appointed representative, your network or principal will usually want to review and approve the arrangement before you begin. The agreement is written for that review. They will want to confirm that the firm is making introductions only, that no regulated activity is happening beyond your permissions, and that data and consent are handled correctly.
If you are directly authorised, the same review happens through your own compliance function. Either way, bring the introducer agreement and a plain description of the allowed-and-not-allowed line to the people who sign it off, and let them confirm the detail for your firm. E&G is used to supporting that review.
You keep records of consent and of the introductions you make. You keep your staff trained on the line between introducing and advising. You keep to that line in every case. And you review the arrangement periodically, as you would any other.
This is ordinary record-keeping and oversight, applied to an introducing role with clear limits. Ask your compliance team to confirm the specifics for your firm before you start.
No. You act within the mortgage and protection permissions your firm already holds. E&G provides the regulated advice on pensions, investments and estate planning under its own FCA authorisation, firm reference number 474163. Introducing clients to an authorised firm does not require a variation of permission.
E&G. They give the regulated advice, document its suitability and carry the PI cover for it. Your exposure is limited to the introduction and the recorded consent, because you do not give the regulated advice.
The client's consent, recorded at the point of introduction. Nothing is shared before the client agrees, and the client is told the introduction is being made. Each firm is responsible as data controller for its own handling of the information.
No. The introducer agreement is written to be reviewed and approved by a network or principal. They will confirm that the firm introduces only, stays within its permissions, and handles data and consent correctly. E&G is used to supporting that review.
Who the E&G advisers are, what their advice covers, and how your client is looked after from the first call onwards.
Read it
From 6 April 2027 most unused pension funds count towards the estate for inheritance tax. What that changes for mortgage clients who planned to pass their pension on, and where an introduction fits.
Read it
A gifted deposit puts a second household's finances on your file. What the lender needs from the parents, what the gift does to their estate and retirement, and how to introduce them.
Read itYour 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.