Acceptable AR firm types
Due to the restrictions imposed by the Appointed Representative Regulations, Resolution will consider only the following types of ARs:
• Equity crowdfunders
• Peer-to-peer lenders
• Corporate finance advisers
• Financial advisers
• Fund advisers
• Fund intermediaries
• Insurance intermediaries
• Lead generators
Sign an AR agreement with Resolution
After due diligence is performed and the AR appointment is recorded on the FCA’s Financial Services Register, your agreement will be in force. Fees are paid monthly and will reflect the nature of your regulated business activities.
This is the first stage assessment of the AR firm and its individuals responsible for the day-to-day governance.
This is undertaken by Resolution and is a combination of our own due diligence and the FCA application process. Generally, timescales are a lot shorter than they are for a direct authorisation application.
The average time taken to appoint an AR is four weeks.
The FCA capital adequacy requirement of the AR firm is met by Resolution Compliance. The AR firm is required to demonstrate to Resolution on an ongoing basis that it is solvent.
The AR firm is required to have PI cover in place.
Compliance & supervision
Resolution Compliance provides the compliance framework and issues a full compliance policy suite. A Compliance & Supervision Manager is allocated to the AR firm and is responsible for conducting regular compliance audits and for providing guidance regarding compliance matters.
Your regular compliance reporting to Resolution will be conducted through our own online system, through which regular compliance updates are also issued to ARs.
AR firms are required to be registered with the Information Commissioner’s Office and some may be required to undergo cybersecurity (penetration) tests.
Compliance manuals and training
Resolution Compliance provides a full suite of manuals tailored to your business.
Training and CPD will be provided through our own online training system, the Knowledge Centre.
The AR firm may control client money but not hold it. For firms that require client money arrangements, Resolution will be able to introduce them to a payment services provider.
FCA Gabriel and Connect reporting
Resolution Compliance, as a regulated firm, reports directly to the FCA in relation to all of its ARs. It also deals with all Connect issues, such as the approval of Approved Persons for AR firms.
Your clients remain yours, Resolution Compliance never takes ownership of them.
Progression to direct FCA authorisation
You can choose whether to remain as an AR firm with Resolution Compliance or to apply in due course for direct authorisation. If you choose direct authorisation, the application will be handled by Resolution’s associated compliance adviser, Thistle Initiatives Ltd.
FCA application fees are (in most cases), £1,500 for straightforward applications, £5,000 for moderately complex applications and £25,000 for complex applications. Thistle will charge a separate fee based on a standard tariff.
The FCA has a Service Level Agreement under which it can take up to six months to process an application it deems to be complete and twelve months for an application it deems to be incomplete.