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Work with H D Consultants and Become an Approved Introducer
However, as much as we are happy to receive professional introductions, there are many FSA rules and regulations, as well as best practice guidelines to follow first.
Please read our FAQ's below, and if you would like to progress a discussion with H D Consultants, please contact us
here.
Frequently Asked Questions
1. What is an Introducer?
An Introducer is an individual or firm who has a commercial interest in passing client details to H D Consultants, with a view to any type of regulated business being conducted. Introducers range from estate agents to firms of Solicitors.
2. Are there different types of Introducer?
Introductions are split into the following two categories in accordance with FSA requirements.
Mortgage, equity release, investment and pension introductions
Any individual or firm who introduces any of the above categories of leads must be appointed by H D Consultants as an Introducer.
Any Introducer receiving a reward or advantage relating the sale of an insurance contract will need to become an Introducer Appointed Representative (IAR) of H D Consultants (see ‘Insurance introductions’ below).
Insurance introductions
Where an introducer passes on client details to H D Consultants with a view to effecting an insurance contract, (e.g. term assurance, critical illness plans, PHI, ASU, PMI and B&C) or receives any reward in connection with the sale of an insurance contract, then the introducer must become an Introducer Appointed Representative (IAR) and be registered with H D Consultants, our Principal 'Personal Touch Financial Services Ltd' and the FSA, unless an exemption applies (see question 4 below).
3. What is an Introducer Appointed Representative (IAR)?
The Insurance Mediation Directive defines introducing insurance business as a regulated activity and requires introducers to be registered with the FSA, which is a straight forward process as they will not be giving any advice and therefore not subject to the full FSA regime that applies to AR’s.
IAR’s are permitted to introduce clients but cannot undertake any other regulated activity (e.g. fact-finding, issuing illustrations or advising clients).
4. Are there any exemptions so introducers do not need to become an IAR?
Yes. There are two exemptions available.
Professional firms - the FSA permits Solicitors, Surveyors, Accountants and Actuaries to carry on insurance mediation activities in the course of their professional activities. Such professional firms need to be authorised by the FSA as exempt professional firms (EPF) to carry on insurance mediation activities.
A professional firm’s status can be checked online via the FSA’s EPF firms register to ensure they are entitled to use this exemption.
There is no requirement to register an EPF as an IAR where insurance leads are provided, however the EPF must be approved by our Principal 'Personal Touch Financial Services Ltd.'.
Other FSA authorised firms - where the regulated firm/individual does not have relevant permission in relation to insurance, or approval from their principal to effect insurance business, they will need to vary their permission accordingly. The individual/firm also must be approved by our Principal 'Personal Touch Financial Services Ltd.'.
5. What is the difference between an AR and an IAR?
AR’s are authorised to provide advice on and arrange regulated products, whereas IAR’s can only introduce clients to an AR and distribute basic financial promotions on behalf of the AR.
6. What client information can an Introducer provide?
The FSA have stated that Introducers can only provide the following client details:
Name;
Address;
Contact details;
When best to contact;
Under FSA rules the introduction type can be stated (e.g. mortgage or insurance), however, gathering information about clients’ requirements in connection with regulated activities is not permitted (e.g. their income details).
7. What must Introducers disclose to clients?
Before making the introduction, the Introducer must inform the client:
If the Introducer is a member of the same group of companies as the
AR;
Details of any payment the Introducer will receive by way of a share of the commission;
An indication of any other advantage arising out of the introduction such as office space, travel expenses, subscription fees etc.
8. Can the introducer handle any client money (e.g. valuation fees)?
The Introducer must not receive any money in connection with the transaction the client will enter into with the lender/provider as a result of the introduction. In other words, the Introducer cannot accept payment due to the lender/provider, e.g. valuation fees or arrangement fees.
The only money the Introducer may receive is money rightfully owing to them on their own account. So, an estate agent, for example, would be able to receive money due to him for the sale of the house but not in relation to valuation fees.
9. Can Introducer’s advertise the services of H D Consultants
AR’s?
Where Introducers wish to make a financial promotion by advertising H D Consultants' services in their marketing material (e.g. within their Shop Fronts or Websites), H D Consultants have a duty of care to ensure that the promotion complies with FSA requirements. There is a responsibility to ensuring that all Introducer literature that refers to H D Consultants' services is submitted to the Compliance and Financial Promotions team at our Principal 'Personal Touch Financial Services Ltd.'. for approval before use.
If an Introducer wishes to purely confirm that they act as Introducers, this would not be classed as a Financial Promotion providing certain wording is used.
If you would like to progress a discussion with H D Consultants, please contact us
here.
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