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Do appointed representatives need their own complaints procedure?
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Plain English

No — appointed representatives (ARs) do not need their own complaints procedure. The principal firm is on the hook for any complaint about regulated activities the AR carries out. In practice the AR simply uses the principal's procedure, and the principal has to oversee that they're following it properly. This matters because customers need a single, clear route to complain, and the FCA holds the principal accountable for fair treatment end-to-end.

Technical & regulatory detail

Under DISP 1.1.5R and DISP 1.1.7R, a principal is responsible for complaints concerning the conduct of its appointed representative in carrying on regulated activities for which the principal has accepted responsibility (see s.39 FSMA 2000).

Operational consequences:

  • The principal's DISP 1.3 complaint-handling procedure applies to AR-handled complaints.
  • The AR must forward complaints promptly to the principal, or handle them under the principal's procedure with the principal retaining accountability (DISP 1.7).
  • Final responses must be issued within 8 weeks (DISP 1.6.2R), and complainants must be told of their right to refer to the Financial Ombudsman Service.
  • Under SUP 12.6.6R, principals must monitor AR compliance, which extends to complaints quality assurance and root-cause analysis (DISP 1.3.3R).
  • Consumer Duty (PRIN 2A) requires the principal to evidence good outcomes for AR customers, including support and redress.
Source links
Anchor — Vectrex Living Compliance Manual

For internal guidance, refer to Anchor — Complaint Handling Rules and Anchor — Appointed Representatives: Complaints. Anchor is a living manual; check the current entry for the latest version.

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