#1243. AR Application

Transcription

1 #1243 AR Application Guide 2015

2 CONTENTS 3. Introduction 4. Application Requirements 5. What does a good application look like? 6. Decision In Principle (DIP) 6. Due Diligence Checking 6. Outstanding Documentation and Appointed Representative Agreement 6. Induction Course 7. FCA Authorisation 7. Personal Touch Authorisation 7. 6 Month Competency Scheme 8. Appendix 1 - Qualification Requirements 9. Appendix 2 - Useful Contacts 10. Appendix 3 - AR Application Form Guide 2 AR APPLICATION GUIDE 2015

3 INTRODUCTION Prior to an appointed representative (AR) joining Personal Touch Financial Services Limited, or an adviser joining a Personal Touch AR as a registered individual (RI), it is necessary to establish whether they can be considered fit and proper, as defined by the Financial Conduct Authority (FCA), and whether they constitute any form of business risk to Personal Touch. This guide provides you with an overview of the process for joining Personal Touch through to obtaining authorisation and competent status. As a network we must ensure that an AR or RI is of sufficiently good repute and that they possess appropriate general, commercial and professional knowledge. This will ensure they can accurately communicate all relevant information regarding any proposed service to a client or potential client. (SUP 12, 3

4 APPLICATION REQUIREMENTS To begin the application process and for your AR application to be taken into consideration, we require the following: Firm Requirements Completed appointed representative application form Latest set of company accounts (if applicable) including profit and loss and balance sheet Last RMAR report (only for firms that have been directly authorised by the FCA) Copy of the firm s data protection licence Individual Requirements (controllers and advisers) Completed registered individual application form Certified copy proof of a valid government issue photo identification (i.e. driving licence or passport) Personal credit report using one of the below credit agencies: Experian - Equifax - Noddle - A copy of your last residential mortgage statement if your mortgage does not appear on your credit report Copy of all relevant certified financial services qualification certificates please see appendix 1 Please note: application forms will need to be signed and dated within the last 6 months. All documents will either need to be ed to the financial and propriety team at financialandpropriety@personaltouchfs.com or posted to: Financial and Propriety Personal Touch Financial Services Limited Trinity 3 Trinity Business Park Solihull B37 7ES Please see appendix 3 for more information about completing the application form. 4 AR APPLICATION GUIDE 2015

5 WHAT DOES A GOOD APPLICATION LOOK LIKE? Good Quality Applications Poor Quality Applications Financial Soundness Credit History No history of CCJs / IVA / bankruptcy. Current CCJs / IVA. Unsecured Debt Less than 5,000 of unsecured debt (in excess of cash / savings). All debts are up-to-date. More than 30,000 of unsecured debt (in excess of cash / savings). Debts are not managed well visibility of arrears and use of payday loans. Overall Financial Position Overall financial position is at least 10,000**. Overall financial position is in excess of - 10,000**. Industry Debt Industry debt of less than 500. Industry debt of 5,000 or more or there is no agreement for repayment in place for any amount. Property Ownership (controllers only) Controller has ownership of property. Controller does not have ownership of property. Honesty, Integrity and Reputation Disclosure Convictions Full and proactive disclosure of all information requested on the application form. No criminal convictions, cautions or proceedings (including traffic offences that did not lead to a ban). Employment and Conduct Non-disclosure of any information requested on the application form. Criminal convictions, cautions or proceedings (including traffic offences that did lead to a ban). Lender Panel Removal No current and / or historic panel removals. Current and / or historical panel removals. Disciplinary action Has not been subject to any disciplinary action. Has been subject to disciplinary action. Previous refusals, restrictions or dismissals Historic Investigations Breaches Employment Gaps Upheld Complaints Has never been refused, restricted, disqualified, suspended or removed from trading from any position. Never been subject to investigations or allegations of misconduct or malpractice or been investigated or been found to have been carrying out unauthorised regulated activities. Has never received a breach in relation to their regulated activities. Full education and / or employment history provided for the preceding 10 years and employment history is consistent with the FCA register. No upheld complaints recorded against them. Has been refused, restricted, disqualified, suspended or removed from trading from any position. Has been investigated for carrying out unauthorised activities or the subject of an allegation of misconduct or malpractice. The allegations were substantiated. Has received a breach in relation to their regulated activities and this was of a serious nature. Full education and / or employment history not provided or not consistent with the FCA register and there is no plausible explanation. One or more upheld complaints recorded against them that have resulted in customer detriment or complaints which are currently being investigated. Competency and Experience Competence and Capability The applicant is fully competent and has previous financial services experience. The applicant is non-competent, has no previous financial services experience and is applying to become a controller. ** Please note that vehicle values and any corresponding liabilities such as hire purchases are not taken into consideration. 5

6 APPLICATION PROCESS DECISION IN PRINCIPLE (DIP) Once we have received all relevant documentation, the application will go through an initial vetting stage to determine whether it meets our criteria by reviewing the fitness and propriety of the firm, controllers of the business and any advisers. We will decide whether the application fits our criteria and proceed to accepting or rejecting the application. Should the application be accepted, it will then move onto the due diligence stage. DUE DILIGENCE CHECKING The application will be passed to the financial and propriety analyst, who will carry out due diligence checking using third party information. This is a more in-depth check into the background of the firm, controllers and any advisers to determine whether they are fit and proper. Some of the checks include employment referencing and a criminal records bureau check. It is important to ensure that we are aware of any adverse information, as non-disclosure will lead to the rejection of an application. At this point, member relations will be informed that your application is being processed and they will be able to support you in the on-boarding process. OUTSTANDING DOCUMENTATION AND APPOINTED REPRESENTATIVE AGREEMENT Once the due diligence checking has been completed, we may require further information or documentation as a result of their findings. These may be bank statements to cover periods of unemployment or details of roles and responsibilities of other directorships. The appointed representative agreement is a legally binding agreement between a firm and Personal Touch. It sets out the basis / requirements upon which Personal Touch appoints its ARs. It is also an FCA requirement that every AR with Personal Touch has an official legal document in place. INDUCTION COURSE Once due diligence checks have been completed and all outstanding information has been provided to Personal Touch s satisfaction, any selling controllers and advisers will be booked onto the next available induction course. These are paid for by Personal Touch and a lunch is provided. Any travel or accommodation costs are not provided or covered by Personal Touch. Induction courses run once a month and usually take place during the first full week of the month. Individuals attending the course may be required to carry out pre-course testing, which will need to be completed prior to attending the course. This course covers: Introduction to Personal Touch The back-office system (Toolbox) Mortgage, protection and general insurance products Product areas may be covered on different days (Monday Thursday) and you are only required to attend those days that relate to your chosen product areas. For products not covered under mortgage, protection and general insurance, courses are booked upon request on an ad hoc basis. You are required to pass all elements of the course prior to your authorisation. 6 AR APPLICATION GUIDE 2015

7 AUTHORISATION PROCESS FCA AUTHORISATION Any directors, partners and investments and pensions advisers will be required to complete the FCA s Long Form A UK and overseas firms (not incoming EEA). The financial and propriety team will send you a copy of this form. You will need to complete this and return it to Personal Touch for the financial and propriety analyst to review and submit to the FCA on your behalf. This allows the FCA to record the firm, controllers and investment and pension advisers on their register for controlled functions. The firm will need to show on this register before Personal Touch are able authorise the firm, as per FCA guidelines. The FCA works to the following application turnaround times: AR sole trader AR Ltd / LLP / partnership Director / partner Wealth adviser authorisation 3 to 5 working days 7 to 14 working days 7 to 14 working days 7 to 14 working days PERSONAL TOUCH AUTHORISATION Once all of the above points have been covered and any outstanding items and information have been obtained, Personal Touch will review the firm application file and sign the file off. Toolbox authorisations can then be put in place. This means your firm can begin booking appointments with clients and assisting them in purchasing financial products. Sourcing systems will be ordered for any advisers by the financial and propriety team. You will receive a phone call and from us to guide you in your authorisation and assist with any queries you may have. Staff within Personal Touch will be notified and your member competence consultant (MCC) will contact you to book a visit. Your dedicated member contact team can help you with any queries after authorisation and can be reached on or alternatively at membercontact@personaltouchfs.com. 6 MONTH COMPETENCY SCHEME Upon authorisation, your MCC will make contact to put a bespoke competency plan in place for your firm and all advisers. The MCC will discuss any further training needed or areas for improvement to achieve the required standards. A development plan will be designed and implemented within a maximum of 30 days or at the 4 week visit. To progress towards competent adviser status (CAS), the standards need to be achieved in the main performance areas of this stage. These areas include: Observed interviews File quality Performance reviews including KPIs Knowledge testing / personal development / continuing professional development (CPD) The specified standards must be achieved within 6 months of authorisation through Personal Touch. The minimum period before nomination for sign off to attaining competence is 3 months from authorisation. 7

8 APPENDIX 1 - QUALIFICATION REQUIREMENTS Product Area Investments and Pensions Long Term Care Occupational Pension Transfers Protection Personal Insurance Private Medical Insurance Mortgages Equity Release Qualification Required Level 4 qualified: Diploma in Financial Planning (CII) or Diploma for Financial Advisers (IFS). Other qualifications may be acceptable if encountered. Level 4 qualified: Diploma in Financial Planning (CII) and CF8 or Diploma for Financial Advisers (IFS) and CF8. Level 4 qualified: Diploma in Financial Planning (CII) and G60, or AF3 or Diploma for Financial Advisers (IFS) and G60, CF9, or AF3. No qualifications are currently required. No qualifications are currently required. No qualifications are currently required. CeMap 1, 2, 3 or CF 1 and 6 or FPC 1, 2, 3 and MAQ or CeMap Bridge or CF6 or RO1 and CF6 Or Inexperienced - FPC1, CeFA1, CeMap1, CF1 - Must pass full mortgage exam within 6 months of authorisation. Cannot be deemed competent without full qualification. Same requirements as mortgage authorisation plus ER1 or CeRER or CF7 and HR1 or CeLTM and CeRER top-up exam. 8 AR APPLICATION GUIDE 2015

9 APPENDIX 2 - USEFUL CONTACTS During the application process you may have queries and questions. Our dedicated teams listed below are available to assist you through the application: FINANCIAL AND PROPRIETY The financial and propriety team are here to support you throughout the on-boarding process. Any queries relating to your application can be directed to: financialandpropriety@personaltouchfs.com Telephone: Fax: MEMBER RELATIONS Helen Jones and Karen Ward are available to provide additional support to you and the business you are joining throughout your application and beyond. Helen and Karen can be reached by: memberrelations@personaltouchfs.com Telephone: / 1151 MEMBER CONTACT Our member contact team are available for any general queries you may have. They can be reached on: membercontact@personaltouchfs.com Telephone: FINANCIAL PROMOTIONS During the application process you will need to submit a business card for approval. Our financial promotions can assist you with this and any queries regarding it. You can reach financial promotions by: fp@personaltouchfs.com Telephone: TRAINING AND DEVELOPMENT TEAM Our dedicated training resourcing team will assist you in your pre-course testing and lead your induction course. Any induction course and testing queries can be directed to: memberdevelopment@personaltouchfs.com Telephone: HEAD OFFICE POSTAL ADDRESS Trinity 3 Trinity Business Park Solihull Birmingham West Midlands B37 7ES 9

10 APPENDIX 3 - AR APPLICATION FORM GUIDE SECTION 1: MAIN FIRM DETAILS The trading details and contact details of the firm need to be provided here, as these will be recorded to identify the firm on our systems. SECTION 2: REGULATORY STATUS OF COMPANY The FCA details of the firm need to be accurately noted, including the name of any previous networks the firm has been an appointed representative of. We use these details to identify your firm on the FCA register. SECTION 3: FIRM TRADING DETAILS You are required to declare any other business your firm is involved with or connected to. This includes any introducers, networks, referrals to other businesses and how your business operates; including face-to-face, telesales and client incentives. We will be able to set up your introducer agreements for Personal Touch and approve any incentive schemes you offer. You will also need to tell us which products your firm will be authorised for and the details of your trading licences. SECTION 4: FIRM BANK DETAILS The bank details of the firm will be used to pay any commissions due and any other financial transactions. If the firm is an LLP or limited company, the bank account name will need to be in the legal entity name of the firm. SECTION 5: FIRM FINANCIAL DETAILS We require the details of the expected income the firm will receive from the products it retails in for the next 12 months. 10 AR APPLICATION GUIDE 2015

11 SECTION 6: FIRM ASSETS AND LIABILITIES You will need to detail the assets and liabilities of the firm only. This section should only be completed for limited, LLP or partnership firms. This section and section 5 allows us to see how solvent the firm is. SECTION 7: ADMINISTRATION STAFF AND CONTROLLERS OF BUSINESS If the firm employs any administration staff we require their details so we are able to provide them with log-in details to our back office system. Any other controllers details may be noted here so we are able to provide them with log-in details to our back office system. All directors (including non-selling) will also be required to complete a registered individual application form. SECTION 8: FIRM CREDIT AND REGULATORY HISTORY The questions in this section need to be answered and any adverse information will need to be fully explained. Failure to answer questions or non-disclosure may result in the application being rejected. SECTION 9: DECLARATION One director of the firm will be required to sign and date the declaration. This declaration is to note that the information provided is true and accurate. It also gives their permission for Personal Touch to carry out any necessary background checks to ensure the firm is fit and proper. SECTION 10: CONTINUATION SHEET This sheet may be used to note anything to support the application or to expand and explain information provided within the application. 11

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