What is an Appointed Representative? An appointed representative, often called an AR, is a person or firm that conducts agreed regulated business under an authorised principal firm.
In a mortgage network, the network’s authorised firm normally acts as the principal. It accepts regulatory responsibility for the activities included within the appointed representative agreement.
The AR is not independently authorised for those activities. However, this does not remove the adviser’s professional responsibility. The adviser must still provide suitable advice, maintain accurate records and follow the principal’s approved procedures.
At a Glance
- An appointed representative operates under an FCA-authorised principal.
- A written agreement defines the regulated activities the AR may conduct.
- The principal accepts responsibility for the activities covered by that agreement.
- The AR must follow the principal’s compliance, supervision and financial promotion requirements.
- Permissions depend on the principal’s approval, the adviser’s competence and the agreed business scope.
- AR status is different from being directly authorised by the FCA.
How Does the Appointed Representative Structure Work?
The appointed representative model has two main parties.
The principal firm
The principal is the FCA-authorised firm responsible for overseeing the appointed representative.
Before making an appointment, the principal must assess whether the proposed AR is suitable. This can include its ownership, financial position, experience, competence, business model and senior management.
The principal must also maintain an effective supervision structure after the appointment begins.
The appointed representative
The appointed representative may be an individual adviser, partnership or company.
It enters into a written contract with the principal. That contract defines the business the AR may conduct and the conditions it must follow.
The AR must remain within that approved scope. It cannot assume that joining a mortgage network provides unrestricted access to every regulated activity or product area.
The FCA provides further information about the responsibilities of principal firms and appointed representatives.
What Does an Appointed Representative Agreement Cover?
The written agreement is central to the AR relationship.
It should establish:
- which regulated activities the AR may conduct;
- which products or advice areas are approved;
- how supervision and file checking will operate;
- what records the AR must retain;
- how financial promotions must be approved;
- what information must be supplied to the principal;
- how remuneration and charges are handled;
- what happens if the arrangement ends.
The precise terms vary between networks. Advisers should therefore examine the agreement, fee structure and operating requirements before accepting an appointment.
The wider Connect appointed representative model explains how Connect supports firms entering this structure.
What Mortgage Activities Can an AR Conduct?
An appointed representative may only conduct the activities covered by the principal’s regulatory permissions and the written AR agreement.
Depending on approval, experience and competence, these may include:
- advising on regulated residential mortgages;
- arranging regulated mortgage contracts;
- buy-to-let mortgage business;
- mortgage protection;
- general insurance;
- other approved finance activities.
Some business, including parts of commercial finance and buy-to-let lending, may fall outside FCA mortgage regulation. However, network procedures and other regulatory requirements may still apply.
An adviser must not assume that experience in one area creates permission to advise in another. Additional training, assessment or supervision may be required before the business scope changes.
What Is the Principal Responsible For?
The principal accepts regulatory responsibility for the AR’s activities covered by the appointment.
Its duties include:
- completing checks before appointing the AR;
- confirming the activities the AR may conduct;
- notifying the FCA about the appointment;
- providing suitable systems and controls;
- monitoring advice and business activity;
- reviewing financial promotions;
- assessing competence and conduct;
- keeping regulatory information accurate;
- taking action when standards are not met.
Oversight should reflect the size, complexity and risk of the AR’s business.
The purpose is not simply to check completed files. Effective oversight should identify whether clients are receiving suitable advice and whether the AR is operating within its agreed scope.
Read more about mortgage network compliance support.
What Is the Adviser Still Responsible For?
An appointed representative does not transfer every responsibility to the network.
The adviser remains responsible for completing the work properly. This includes:
- gathering accurate client information;
- assessing affordability and suitability;
- researching appropriate options;
- explaining risks, costs and limitations;
- recording the reasons for a recommendation;
- treating clients fairly;
- protecting personal information;
- maintaining professional competence;
- following the principal’s procedures.
A regulatory framework can support good advice, but it cannot replace professional judgement.
Structure defines the boundaries. The quality of the advice still depends on how carefully the adviser works within them.
How Are Financial Promotions Controlled?
Mortgage websites, social posts, advertisements, brochures and lead-generation material may be financial promotions.
An AR must follow the principal’s approval process before publishing regulated promotional content. The material must be clear, fair and not misleading.
The principal may require:
- standard regulatory wording;
- approval before publication;
- records of approved versions;
- balanced explanations of benefits and risks;
- withdrawal of outdated material;
- checks on introducer or lead-generation activity.
This requirement can apply even when the appointed representative trades under its own business name.
How Is an AR Shown on the FCA Register?
An appointed representative should appear on the Financial Services Register in connection with its principal.
Clients and professional contacts can use the register to check:
- the AR’s legal or trading name;
- its current status;
- the principal responsible for it;
- the activities connected with the appointment;
- relevant contact details.
AR firms should ensure their website, correspondence and regulatory disclosures accurately describe their status.
They should not imply that they are independently FCA-authorised when they operate as an appointed representative.
Appointed Representative or Directly Authorised?
An AR operates under the regulatory responsibility and controls of a principal firm.
A directly authorised firm holds its own FCA permissions and manages its regulatory responsibilities directly.
An AR may receive
- an established compliance structure;
- supervision and file review;
- approved systems and processes;
- lender and provider access;
- training and regulatory updates;
- technology and case-management support.
A directly authorised firm may have
- greater direct control over its regulatory arrangements;
- direct responsibility for FCA reporting;
- responsibility for maintaining its own systems and controls;
- greater internal compliance resource requirements;
- direct responsibility for its regulatory permissions.
Neither structure is automatically suitable for every mortgage business. The decision should reflect the firm’s experience, scale, resources, intended activities and preferred level of operational control.
Advisers considering the AR route can review the Connect AR onboarding process.
How Connect Supports Its Appointed Representatives
Connect for Intermediaries operates as a mortgage network for advisers working across mainstream and specialist markets.
Subject to individual approval and permissions, support can include:
- structured compliance supervision;
- mortgage and protection systems;
- access to lender and provider relationships;
- training and continuing professional development;
- case placement support;
- business development resources;
- operational guidance.
The technical foundation remains the principal and AR relationship. Network services sit around that foundation to help the adviser operate effectively.
Experienced advisers can review the full Connect mortgage network proposition.
How Connect Experts Relates to the AR Network
Connect Experts is the adviser directory and matching platform within the wider Connect Group structure.
Advisers listed on the platform are part of the Connect network or associated authorised firms. The directory does not provide mortgage advice directly. Advice is provided by the selected adviser or firm.
Eligible Connect ARs may receive a public profile that helps people search by location, language, adviser preference and mortgage type.
This gives the regulatory structure a clear public connection. Connect Network supports the adviser’s business, while the Connect Experts mortgage adviser directory helps consumers find individual advisers.
Apply to Become a Connect Appointed Representative
Becoming an appointed representative is a regulated business arrangement, not only a membership decision.
Connect will need to understand your experience, intended business, qualifications, ownership, permissions and support requirements before an appointment can proceed.
Review the requirements and join Connect Network to begin the discussion.
Frequently Asked Questions
What is an appointed representative mortgage broker?
An appointed representative mortgage broker conducts agreed regulated activities under the responsibility of an FCA-authorised principal firm.
Is an appointed representative FCA-authorised?
An AR is generally not independently authorised for the activities covered by its appointment. It operates under an authorised principal’s responsibility.
Does an AR need a written agreement?
Yes. The agreement defines the business the AR may conduct and records the principal’s responsibility for the activities it accepts.
Can an AR offer every type of mortgage?
No. The AR may only conduct business covered by the principal’s permissions, the written agreement and the network’s approval.
Who checks the AR’s mortgage advice?
The principal must maintain suitable oversight. This may include file reviews, supervision, competence assessments and monitoring of business activity.
Can an appointed representative use its own brand?
A network may permit an AR to retain its trading identity. Branding, websites and financial promotions must still follow the principal’s requirements.
Who is responsible if an AR gives regulated advice?
The principal accepts regulatory responsibility for the AR’s activities included within the appointment. The adviser must still follow the required advice and conduct standards.
Can an established brokerage become an AR?
Yes. The AR structure can be used by experienced advisers and established firms, subject to the principal’s assessment and approval.
Does an AR appear on the FCA Register?
An appointed representative should be recorded on the Financial Services Register in connection with its principal firm.
How can I become a Connect appointed representative?
The process begins with an assessment of your experience, business structure, intended activities, qualifications and support requirements.
Frequently Asked Questions
What is an appointed representative?
An appointed representative is an adviser or firm that conducts specified regulated activities under the responsibility of an FCA-authorised principal firm.
Does an appointed representative need separate FCA authorisation?
An AR does not usually hold separate authorisation for the activities covered by its appointment. It operates under the relevant permissions of its principal.
Is an appointed representative regulated?
The FCA supervises the principal firm, while the principal oversees the AR. The AR must follow the relevant FCA rules and the principal’s regulatory procedures.
Can an appointed representative use its own business name?
Many AR firms retain their own trading name. However, branding, websites and financial promotions normally require approval under the principal’s procedures.
Can an AR use every lender?
Not automatically. Lender access depends on the principal’s panel, the AR’s permissions, lender criteria and any relevant accreditation requirements.
Is an introducer appointed representative the same as an AR?
No. An introducer appointed representative generally introduces customers but cannot provide regulated advice. A full appointed representative may conduct the regulated activities specified in its agreement.
Who handles complaints about an appointed representative?
The AR must follow the principal’s complaints process. The principal retains responsibility for ensuring complaints concerning regulated activities are handled correctly.
