Enhancing Oversight of Appointed Representatives in Credit Broking: Addressing FCA Concerns

This presentation outlines key issues identified by the Financial Conduct Authority (FCA) in the oversight of Appointed Representatives (ARs) and Introducer Appointed Representatives (IARs) within the credit broking industry. It highlights common shortcomings in due diligence, monitoring, and conflict of interest management, and offers best practices for firms to enhance their oversight processes. The presentation also details how MEMA Consultants can support firms in improving their compliance frameworks, ensuring robust oversight, and aligning with FCA guidelines.

1. Improving Oversight of Appointed
Representatives in the Credit Broking Industry

2. Introduction
The FCA has assessed key harms caused by ARs and IARs in the
credit broking sector.
Focus areas: Due diligence, ongoing monitoring, conflict of
interest, and termination procedures.
Importance of addressing these issues for better oversight.

3. Key Issues Identified by the FCA
Inadequate Understanding:
Poor understanding of AR requirements.
Inadequate systems and controls for due diligence.
Insufficient Monitoring:
Lack of resources for effective oversight.
Conflicts of Interest:
Potential conflicts between commercial and compliance functions.
Inadequate Termination Procedures:
Failure to update AR websites post-termination.
Outdated offboarding policies.

4. Best Practices for Improving AR Oversight
Robust Due Diligence:
Initial and ongoing checks on ARs' suitability.
Adequate Resources:
Sufficient staff and controls for AR oversight.
Independent Oversight:
Dedicated compliance-focused staff.
Termination Procedures:
Well-documented and properly executed termination processes.

5. How MEMA Consultants Can Help
Due Diligence Guidance:
Comprehensive checks to meet FCA requirements.
Monitoring Framework Development:
Robust systems for AR activity oversight.
Resource Optimisation:
Efficient allocation of resources for effective monitoring.
Termination Procedure Design:
Ensuring compliance with FCA guidelines during AR
offboarding.

6. CONTACT US
[email protected]
03301330811

Suite 1810, Unit 3a,34-35 Hatton Gardens, Holborn, EC1N 8DX
https://www.memaconsultants.com/

7. Thank you
for listening!