Download Guidance for Introducer Appointed Representatives

Introducer Appointed Representatives (IAR) Guidance
What are Introducer Appointed Representatives (IARs)?
Businesses (Sole Traders, Partnerships and Ltd Companies) holding a contract to actively promote products,
services and introduce their customers/clients to Openwork Limited. The Introducer Appointed Representative
(IAR) can receive a fee for any plan sold by the Adviser, as a result of the introduction. Irrespective of whether
a fee is paid or not Openwork complete the appropriate due diligence to enable an Introducer Contract to be
put in place
The Application and vetting requirements for an IAR
The following application is required, and can be downloaded from the Portal or can be obtained via the
Recruitment team:
https://portal.openwork.uk.com/document/5519/Appointed-representative-introducer-application.pdf
This application is designed to enable a simple and quick appointment and FCA authorisation, by obtaining the
information required in a ‘one step’ approach, minimising the need for additional questions or information.
Certified proof of ID, i.e. copy of passport, driving license (with current address) or recent utility bill (showing
current address) should accompany the IAR individual applications.
The Principal of Introducer part of the application form will need to be completed for the Partner / Director of
the IAR responsible for the introductions.
For help with any questions or for further guidance, please contact [email protected], telephone
01793 567741 or visit the Recruitment Portal pages.
What happens next?
Within 48 hours of Openwork receiving your application(s), we will be in touch with the named contact on the
application, to advise if there is any further information required to progress the application.
What are the expected turnaround times?
If any additional information or checks can be responded to and completed within 48 hours, this will enable us
to achieve appointment (subject to demonstrating suitability / FCA authorisation) in 5 - 10 working days.
Registration with the FCA
Recruitment will complete the FCA registration, upon completion of vetting. The FCA turnaround is
approximately 5 working days.
Stationery
Please note, whilst Openwork do not require sight of the stationery we can help in an advisory capacity if you
wish. Please also refer to the FCA website for further information (links are available via the Recruitment page
of the Openwork Portal).
Please note IARs must not use the Openwork logo on their letterheads.
Websites
If the IAR wishes to use a website, please be aware this must be approved in advance by Openwork. Please
call Advertising Approval on 01793 567683.
Who are Introducer Appointed Representatives?
The most popular IAR’s are Estate Agents, UK property developers and commercial loan businesses and
other non financial service businesses with a natural link to introducing financial services, such as mortgage
brokers, sports clubs or will writing companies
Below are a few businesses where restrictions apply
For further guidance on potential Introducers, please contact [email protected] or call 01793
567741.
Solicitor or Chartered / Certified Accountants
Restrictions apply which are due to the regulatory bodies (RPB) rather than the FCA. Effectively, if licensed
by the RPB, they can carry out regulated activities (including making introductions) without the need to be
authorised by the FCA. The onus is on the solicitor or accountant to comply with their Codes of Conduct.
We can vet and contract a solicitor firm as an IAR if they provide a signed statement to confirm they are fully
aware that for the purposes of Protection, Pensions, and Investments, Openwork is a tied network and they
are happy to proceed on this basis.
If a firm appears on the EPF Register at the FCA, please note we will be unable to offer an IAR contract.
Although they will have the permissions to pass on introductions without an IAR contact being required.
Medical Doctors
The General Medical Council (GMC) consider it unethical for Doctors to ‘introduce’ their patients. We would
not wish to offer a contract for this reason.
Registered Charities
Charities are unable to ‘introduce’ as this affects their charitable status.
Prohibited Activities
We will not appoint an IAR that conducts any of the Non-Openwork Business prohibited activities as outlined
in 1.15 of the TCF manual.
‘Mortgage only’ Introductions
It is possible for businesses to make ‘mortgage only’ introductions without being an appointed IAR. This
includes first charge, second charge and Buy To Let mortgages.
Directly Authorised (DA) firms
A firm Directly Authorised by the FCA can only make introductions if they have the relevant permissions
registered against them on the FCA Register. As such an Openwork introducer contract is not required.
To avoid a breach of regulatory requirements, the relevant permissions must be in place to enable a DA firm to
make introductions to an Openwork Enterprise (with exception of mortgage-only introductions as explained
above). Please note, the FCA could also find business conducted by an Openwork Enterprise resulting from
introductions without the appropriate permissions is ‘void’.
A DA firm will be required to apply for these permissions directly from the FCA. The FCA quote 6-12 months
for a permission to be added and there is a cost associated (in the region of £750, depending on the type of
permission to be added) although usually this is obtained within this time. Please be aware that the FCA can
refuse a permission to be added to a firm - this only usually applies in exceptional circumstances.
The permissions required can be checked by looking up the business on the FCA register. As guidance, the
following permissions should be in place (please check the FCA guidance for your own specific requirements):
Permission required to introduce consumer credit business (e.g. secured bridging loans)* Please
contact us to discuss this if this is applicable in a case you are looking at:
Activity Name
Credit broking
Permissions required to introduce pure protection/GI business:
Activity Name
Investment Instrument
Customer Type
Making arrangements with a view to transactions in investments
Non-investment insurance contracts
Commercial
Retail (Non-Investment Insurance)
Permissions required to introduce COB/investment business:
If the Directly Authorised firm is looking to make COB introductions, we would need to understand the type of
business that the firm is looking to introduce as there are specific permissions for each type of business. To
receive full guidance on the permissions required in these instances please contact Recruitment.
To help explain when an IAR contract is required:
Activity (COB or ICOB)
IAR contract
required?
Commercial (If there is a financial reward)
Yes
Regular
Yes
Active (when there is promotion/advertising asking customers)
Yes
Purchased Leads (providing no further adjustment to the amount paid based on the outcome)
No
Passive (for example marketing opportunities only)
No
Regulated Professional Bodies (for example Solicitors/Accountants, not breaching own RPB
rules and not already registered on EPF register)
Yes
First Charge, Second Charge and Buy To Let Mortgages
No
Directly Authorised
No*
*A DA can introduce without an IAR arrangement if correct permissions in place (see DA guidance above)
For help with any questions or for further guidance, please [email protected], telephone
01793 567741 or visit the Recruitment Portal pages