The FCA have published an alert (in August 2016) to highlight some of the risks arising from authorised firms accepting business from unauthorised introducers/lead generators and/or other authorised firms (the introducer). The FCA are very concerned at the increase they have seen in cases in which the introducer has an inappropriate influence on how the authorised firm carries out its business, in particular where the introducer influences the product choice. They also have concerns where the authorised firm delegates regulated activities, for example, by outsourcing their advice process to unauthorised entities or to other authorised firms that do not have the relevant permissions, or are not their appointed representatives. The alert details the areas of concern the FCA have identified and also lists warning signs which firms should consider if they accepting customer introductions from introducers. According to the FCA, it is essential that firms maintain full and complete ownership of the advisory process between themselves and their customer, and any regulated advice a firm provides must meet the requirements set out in the FCA Handbook. Firms have been advised to: • Carry out robust due diligence on the introducers they transact with; • Have in place a robust vetting procedure to ensure that introductions have been sourced legitimately; • Regularly review and ensure that their systems and controls are adequate to demonstrate that they have full and complete ownership of the advice they are providing; • Only recommend products that they understand fully; • Provide independent advice to customers introduced ("independent" in this context means independence from the issuer or product provider); • Not allow another entity, whether or not it is regulated, to use the firm's reference number on the firm's behalf unless they are satisfied that it is being used appropriately; • Only delegate the performance of regulated activities to other authorised firms that have the required permissions or who are the firm's appointed representatives, with appropriate monitoring.

The FCA have published an alert (in August 2016) to highlight…