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Glossary

Introducer Appointed Representative (IAR)

An Introducer Appointed Representative is an AR whose appointment is limited to introducing customers to its principal or the principal's group and distributing non-real-time financial promotions for their products. It cannot advise, arrange or deal. IARs carry a lighter set of SUP 12 obligations, but they are still ARs and the principal is still responsible for them.

What an IAR can and cannot do

  • The contract must limit the scope to effecting introductions and distributing non-real-time financial promotions (SUP 12.5.7R).
  • An IAR may not deal as agent, arrange deals or regulated mortgage contracts, assist with insurance contracts, advise, or do anything that might lead a customer to believe they had received one of those services (SUP 12.2.8G).
  • An IAR may have more than one principal, with a contract with each, and no multiple principal agreement is needed (SUP 12.2.8G, SUP 12.4.5BR).

What still applies

  • The principal must take reasonable care, before appointment and continuously, that the IAR is suitable, at a minimum verifying the identity of the IAR and relevant persons (SUP 12.4.6R, SUP 12.4.7G).
  • IARs are covered by the 30-day notice of a new appointment, the annual self-assessment, REP025 (without non-regulated revenue) and the annual check of AR details.
  • The annual and triggered review rules (SUP 12.6A.2R to 12.6A.4R) and the approved persons regime do not apply to IARs (SUP 12.2.10G, SUP 10A.1.15R).

Common misconceptions

“IARs need no oversight.”
The annual review rule does not apply, but the suitability test is continuing, and IARs must be covered in the self-assessment and in REP025.
“IARs have a shorter notice period.”
PS22/11 considered and rejected that. A new IAR needs the same 30 days' notice as a full AR.
“An introducer and an IAR are the same thing.”
An introducer is an individual appointed by a firm or AR and is not exempt in their own right. An IAR is itself an exempt AR (SUP 12.2.13G).

In Merrin

In Merrin an IAR is a firm type, so the rules that do not apply to it are simply not asked for.

Risk & completeness

Sources

Checked against these sources on . This is general information, not legal advice.

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