Professional & Financial Services

Financial intermediary compliance checklist

A confirmation checklist for financial intermediaries — insurance distributors and loss adjusters, advisers and intermediaries, investment firms and trading venues, fund managers, and pension administrators. Work through the duties every regulated firm shares, then the sections for what you do.

UK-wide
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UK-wide

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Confirm the obligations that apply to your firm are in place. Start with section 1, which applies to every regulated intermediary, then complete the sections for the activities you actually carry on. Everything here applies UK-wide, except claims management regulation, which covers Great Britain only.

Section 1 — Every regulated firm

  1. 1

    Hold the right FCA permissions

    Part 4A permission for each regulated activity you carry on (or, where available, appointed representative status), and meet the threshold conditions on an ongoing basis.

  2. 2

    Operate the SM&CR

    Senior managers approved, certification staff assessed annually, conduct rules embedded — in the limited scope, core or enhanced tier that fits your firm.

  3. 3

    Deliver the Consumer Duty

    Fair value, customer understanding and outcome monitoring wherever retail customers sit in your distribution chain (Principle 12).

  4. 4

    Keep financial promotions compliant

    Every promotion fair, clear and not misleading under the s.21 FSMA restriction.

  5. 5

    Handle complaints under DISP

    DISP time limits and final responses, with Financial Ombudsman Service referral rights.

  6. 6

    Run anti-money-laundering controls

    Risk assessment, customer due diligence, monitoring and reporting under the Money Laundering Regulations.

  7. 7

    Meet operational resilience requirements

    Identify important business services, set impact tolerances and stay within them if in scope.

  8. 8

    Protect personal data and pay the ICO fee

    Handle client financial data under the UK GDPR; unless exempt, register with the ICO and pay the annual fee.

Section 2 — Insurance distribution and loss adjusting

  1. 1

    Hold the insurance distribution permission and meet its conduct standards

    Permission, knowledge and competence, and the distribution conduct rules for everyone in the chain.

  2. 2

    Meet the customer-facing duties

    Demands-and-needs assessment before proposing a policy; product information document for retail customers buying general insurance.

  3. 3

    Protect client money and hold professional indemnity cover

    Insurance client money rules (CASS 5) and the professional indemnity cover the FCA requires for brokers; loss adjusters hold their own PI.

  4. 4

    Meet loss adjusting and claims handling standards

    The permissions for regulated claims handling and the chartered professional standing the loss adjusting profession runs on.

Section 3 — Advisers and intermediaries

  1. 1

    Hold the advising permission and qualifications

    Advising-on-investments permission; retail advisers hold an FCA-recognised Level 4 qualification with an annual Statement of Professional Standing and structured CPD.

  2. 2

    Assess and document suitability

    Gather the client information COBS 9/9A require and issue suitability reports for retail personal recommendations; pension transfer advice on safeguarded benefits needs pension transfer specialist sign-off.

  3. 3

    Hold the right intermediary permissions

    Mortgage intermediary permission (MCOB) for regulated mortgage work; consumer credit permissions for credit broking; FCA claims management permission for regulated claims activity (Great Britain only).

Section 4 — Investment firms and trading venues

  1. 1

    Hold the dealing permission

    Dealing in investments as agent, with the conduct-of-business rules that follow it.

  2. 2

    Protect client money and assets

    CASS segregation, reconciliation and records for client money and custody assets.

  3. 3

    Meet the IFPR and remuneration code

    Own funds and liquidity under the Investment Firms Prudential Regime, the ICARA process, and the MIFIDPRU remuneration code.

  4. 4

    Run venues and reporting lawfully

    MTF/OTF authorisation or RIE recognition; best execution; transaction reporting.

Section 5 — Fund and asset managers

  1. 1

    Hold the managing investments permission

    Discretionary portfolio management is a regulated activity in its own right.

  2. 2

    Run funds under the right regime

    UCITS management rules for retail funds; the UK AIFM regime for alternative funds — full-scope managers appoint a depositary and apply the AIFM remuneration rules; sub-threshold managers register under the lighter regime.

  3. 3

    Disclose climate-related risk

    TCFD-aligned entity and product disclosures if you are a larger asset manager.

Section 6 — Pension administrators

These duties are The Pensions Regulator's and apply even if you hold no FCA permission.

  1. 1

    Support the scheme's TPR obligations

    Registrable information and scheme returns kept current, record-keeping and data quality maintained, and dashboards connection delivered for the schemes you administer — with the industry's non-statutory administrator competence standards (PMI, PASA) as the recognised benchmark.

Related guides

The guides this checklist confirms.