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

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• Outdated offboarding policies.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




contact_at_memaconsultants.com


03301330811



Suite 1810, Unit
3a,34-35 Hatton Gardens, Holborn, EC1N 8DX


https//www.memaconsultant
s.com/

7
Thank you for listening!