A complete, self-contained oversight record for every appointed representative. The 25-item SUP 12 compliance checklist. The per-AR onboarding and due-diligence pack. The 20-item SUP 12.9 records-retention pack. Otto's 5 report formats — including the FCA Dry-Run mock supervisory interview — drafted from your live data in 60 seconds.
Built for the post-Dec 2022 enhanced regime · The module the 2024 FCA Multi-Firm Review of principal firms made unavoidable.
Book a ConsultationPS22/11 raised the bar substantially. The 2024 Multi-Firm Review of principal firms identified seven recurring weaknesses — most of them traceable to one root cause: principals tracking ARs in spreadsheets, drives and consultant decks rather than as living, evidenced supervisory records. The regime now expects active oversight, not appointment paperwork.
The post-Dec 2022 regime requires the governing body to sign off the annual SUP 12 self-assessment. The FCA explicitly looks for this artefact. Most principals can show the assessment was done — far fewer can produce a dated Board minute reference, named SMF signatory and supporting evidence file.
SUP 12.6.13R says ARs flagged Red or Amber must receive intensified supervision — visit-cadence increases, file-review percentages raised, fin-prom approval shortened. The 2019 + 2024 Multi-Firm Reviews flagged this as the single most common gap: principals show RAG ratings but cannot show what changed when the colour did.
SUP 12.6.10G + COBS 4 require the principal to approve every AR financial promotion before issue. The 2024 Multi-Firm Review specifically called out principals who couldn't show pre-issue approval evidence per fin-prom — let alone show their turnaround time when the FCA asked.
SUP 12.9 requires per-AR records for at least 5 years post-termination. Annual reviews, F&P assessments, agreement amendments, monitoring visits, customer-outcome tests, complaints, fin-proms approved, training records, breach notifications. Producing one AR's pack on FCA request, in one sitting, is the test most principals fail.
If your AR oversight lives in spreadsheets, your Board hasn't dated a SUP 12.6A.1R sign-off, and you can't produce a single AR's evidence pack in 30 minutes, the operating system below is for you.
Three things make it the OS, not a spreadsheet. Nine capabilities turn it into the system your SMF runs AR oversight from — day to day, and when the FCA calls. One module covering every SUP 12 obligation — live, scored, evidenced, year-locked.
Most principals run AR oversight from an Excel register and a folder of PDFs — until the FCA asks for one AR's evidence pack. The operating system below is built on three principles that change what the SMF can put in front of a supervisor — and what survives an AR's termination.
Each appointed representative gets its own workspace — onboarding, due diligence, APER people, oversight visits, issues, attestations and gap analysis — isolated and evidenced. When an AR is terminated the record stays intact for the SUP 12.9 five-year horizon. Produce one AR's full pack in a single click.
Otto sits as an FCA Skilled Person and runs the SUP 12 supervisory interview on your live oversight data — RAG-graded answers, examiner observations, signable PDF. Plus four more formats from the same data: the 14-chapter SUP 12 report, Board Quarterly, Executive Summary and a one-page Snapshot.
The score is computed from your live data — section completion weighted across onboarding, oversight, records and attestations, plus the 25-item compliance checklist. Self-certification without evidence is impossible by design; every point traces back to a register row. RAG-rated green, amber or red.
Built for the supervisor visit you haven't had yet, the AR that just went Red, and the board paper due Friday. Every capability ships in the module. No tier gate, no add-ons.
Capture appointment dates, contacts and regulated activities, then build a per-AR permissions & scope map — activity, customer types, geographic reach and restrictions, row by row. The record the FCA expects in place before an AR takes on business.
SUP 12.4 · Per-ARFCA Register check, business plan, accounts, PI insurance, references and beneficial-owner screening — each item tracked Not Requested / Requested / Received, with the evidence file attached. Pre-appointment and ongoing diligence you can prove, not just claim.
SUP 12.4 · EvidencedEvery Approved Person at the AR with controlled functions, F&P assessment and renewal dates, FIT 2.1 disclosures, conduct training and CPD logs — mirrored from People Compliance so the AR's senior people are evidenced to your own standard.
FIT 1.3 · APER · ConductOn-site audits and supervisory meetings logged with RAG ratings, findings and linked remediation actions, plus second-line file reviews — financial promotions, customer outcomes, complaints sampling and T&C. Proof you supervised, not just appointed.
SUP 12.6.10G · RAGWhen an AR is rated Red or Amber, the platform drives the intensified plan SUP 12.6.13R requires — raised cadence, named owner, outcome and next review date. The exact gap the FCA Multi-Firm Review flagged: showing what changed when the colour did.
SUP 12.6.13R · Risk-basedA per-AR register of issues, breaches and complaints — severity, SUP 15 notification status, owner and remediation due date. Anomaly flags auto-suggest issues before they escalate; closed items keep their root-cause analysis and lessons learned.
SUP 15 · Severity-ratedPush periodic attestations to every AR and track them coming back — each submission lands with the AR's self-reported RAG and a full set of answers, then an approve / reject workflow. Network approval rate at a glance; every submission exportable to CSV.
Network-wide · CSVA structured self-assessment across all 14 SUP 12 chapters — Met / Partial / Not Met per question, with notes and attached evidence. It feeds the SUP 12 Health score out of 100; click the score to see exactly why you're at 1 point instead of 2.
SUP 12.6A · Out of 100Full SUP 12 (14 chapters) · FCA Dry-Run mock interview · Board Quarterly · Executive Summary · Snapshot. Same data, five audiences, with the pre-calculated score injected so there's no LLM arithmetic drift. Export to PDF, Word or CSV.
5 formats · PDF/Word/CSV25 checklist controls cited to specific sub-rules. Eight live AR-oversight surfaces feeding a SUP 12 Health score out of 100. 5 Otto formats drafted from your live data — including the FCA Dry-Run mock supervisory interview.
Affordable, modular monthly pricing · No tier gate. No add-ons. No setup fee.
Eight working surfaces — onboarding, due diligence, APER, oversight, issues, breaches, attestations and gap analysis — feeding a transparent SUP 12 Health score out of 100, every point auditable back to its evidence source (auto vs user-attested). A 25-item SUP 12 compliance checklist covers items a–y, and risk-based monitoring surfaces a drifting AR before a supervisor does. Every record feeds Otto’s 14-chapter board-ready SUP 12 report.
The principal's 30-second view of the whole network. A SUP 12 Health score out of 100, RAG-rated, with four live KPI tiles — Active ARs, Approved Persons, open Issues and Attestation status — a section-by-section heatmap and an AR risk-distribution bar. Every appointed-representative obligation on one screen.
Appoint a new AR properly from day one. Capture appointment dates, contacts and regulated activities, then build a full permissions & scope map — activity, customer types, geographic reach and restrictions, row by row. The record the FCA expects in place before an AR ever takes on business.
Pre-appointment and ongoing due diligence in one register. FCA Register check, business plan, accounts, PI insurance, references and beneficial-owner screening — each item tracked Not Requested / Requested / Received, with the evidence attached. SUP 12.4 diligence you can prove, not just claim.
Every Approved Person across the network, fit-and-proper and on file. Controlled functions, F&P assessment and renewal dates, FIT 2.1 disclosures, conduct training and CPD logs — mirrored from People Compliance so the AR's senior people are evidenced to the same standard as your own.
Ongoing oversight, evidenced. Supervisory meetings and on-site audits (SUP 12.6.10G) with RAG ratings and linked remediation actions, intensified monitoring plans for higher-risk ARs (SUP 12.6.13R), second-line file reviews and a conflicts-of-interest register. Proof you actually supervised — not just appointed.
Every AR issue, breach and complaint in one register. Severity, SUP 15 notification status, owner and remediation due date — with anomaly flags auto-suggesting issues before they escalate. Closed items keep their root-cause analysis and lessons learned for the next supervisor who asks.
Push periodic attestations to every AR and track them coming back. Each submission lands with the AR's self-reported RAG, the full question-by-question answers and an approve / reject workflow — network-wide approval rate at a glance, every submission exportable to CSV.
A structured self-assessment across all 14 SUP 12 chapters — onboarding, monitoring, conflicts, terminations, FCA notifications, records and board sign-off. Every question gets a Met / Partial / Not Met toggle, notes and attached evidence, so "where exactly are the gaps?" has an answer before the FCA asks.
Five board-ready report formats from one data set — including the FCA Dry-Run mock supervisory interview Otto runs on your own live AR oversight data. Built from your onboarding, due-diligence, oversight, issues and attestation records, scored out of 100, signable as a PDF. Rehearse the supervisor's questions before the supervisor does.
12 set SUP 12 questions. Each answered from your live AR records — onboarding, due diligence, APER, monitoring visits, issues and attestations. RAG-graded. Examiner observation noted. Signable PDF in 60 seconds.
Every appointment runs through a standard due-diligence pack before the agreement is signed, evidenced per AR under SUP 12.4: FCA Register check, business plan, two years' accounts, PI insurance certificate, two references and beneficial-owner / UBO screening. Each item is tracked Not Requested / Requested / Received with the source document attached. Approved Persons at the AR are assessed against FIT 1.3 with DBS, credit and reference checks held on file. For the most recent appointment (Acme Wealth Ltd, 12 Feb 2026) all eleven diligence items were Received and the agreement scope was mapped to the AR's permitted activities before go-live.
AR oversight accountability sits with the Compliance Oversight function (Ines Kowalski, SMF16), evidenced in the firm's SM&CR Statements of Responsibilities and re-attested in the Q1 2026 review cycle. The governing body receives quarterly AR network MI and signs the annual self-assessment under SUP 12.6A.1R. The firm has not yet formally codified a deputy for the SMF16 in the event of incumbent absence; this is included in the Q2 2026 forward plan for resolution by 30 June 2026.
Apex Mortgages Ltd was moved from Green to Amber on 17 March 2026 after a complaints cluster on suitability. An intensified monitoring plan was opened under SUP 12.6.13R, owned by the SMF16: file-review sampling raised from 5% to 20%, financial-promotion approval moved to monthly pre-issue review, and a supervisory visit was brought forward. Two remediation actions were tracked to named owners; following the June review the suitability sample passed clean and the AR returned to Green.
Otto drafts all 14 chapters of the Board-ready SUP 12 oversight report from your own live records — onboarding, due diligence, APER, agreements, monitoring visits, intensified plans, issues and attestations. Scored out of 100 so a firm cannot claim 100% without the evidence trail to back it up.
An AR register that records appointments but no supervision is the gap the FCA quotes back at every Multi-Firm Review. Every visit, audit and file review here is dated, RAG-rated and remediated; findings become tracked actions with a named owner and due date.
| Owner | AR & scope | Date | Outcome |
|---|---|---|---|
|
Ines Kowalski
SMF16 · Compliance Oversight
|
Annual oversight visit: Acme Wealth Ltd (AR). Full file review, financial-promotion sample and complaints check against the agreed scope of appointment. | Mar 17, 2026 | Green · Pass |
|
Clara Montalvo
Compliance Monitoring · 2LoD
|
Customer-outcome file review: Apex Mortgages Ltd (AR). 12-file suitability sample under Consumer Duty; one unsuitable recommendation identified. | Feb 24, 2026 | Amber · 2 actions |
|
Daniel Ofori
Financial Promotions · 1LoD
|
Financial-promotion approval audit: Atlas Protection Ltd (AR). 20 fin-proms sampled for pre-issue approval evidence under COBS 4 / SUP 12.6.10G. | Feb 06, 2026 | Green · Pass |
|
Ines Kowalski
SMF16 · Compliance Oversight
|
Intensified monitoring review: Borealis Capital Ltd (AR, Red). Monthly cadence under SUP 12.6.13R after a SUP 15 breach; PI cover lapse identified. | Jan 22, 2026 | Red · remediation Q2 |
SM&CR, proved. The Compliance Oversight function owns the AR oversight programme, the executive operates it, and the Board Chair attests under SUP 12.6A.1R. Once locked, the report stays traceable to the underlying AR records and reproducible for every review the FCA runs across the SUP 12.9 five-year retention period.
Otto is trained on SUP 12.2 through 12.9, FIT 1.3 and APER, the post-Dec 2022 enhanced AR regime (PS22/11), SM&CR accountability and the FCA's Multi-Firm Reviews of principal firms. It answers your AR oversight queries in seconds, and drafts your choice of Full SUP 12, FCA Dry-Run, Board Quarterly Pack, Executive Summary or SUP 12 Snapshot — all from the live AR records your firm has actually populated.
Otto does two things for AR oversight. First, it answers any SUP 12 query your team throws at it; rule-cited, handbook-grounded, with the specific figure from your own records where relevant. Second, it drafts five different report formats from the same data, sized for the audience: a 14-chapter Full SUP 12 for the regulator, a Board Quarterly Pack for governance, a 1–2 page Executive Summary for the CEO, a SUP 12 Snapshot for the Compliance Officer, and a 12-question FCA Dry-Run mock supervisory interview that RAG-rates each answer in your firm's own voice. Speed via Otto AI, underpinned by 1,500+ expert documents.
“What due diligence must we hold before appointing an AR?” “When does SUP 12.7 require us to notify the FCA?” “What does intensified monitoring under SUP 12.6.13R actually require?” Otto answers from the handbook, SUP 12, the AR policy statements and your live AR records in seconds, with citations.
Otto drafts your choice of 5 report formats from the same live data in seconds — the regulator gets the Full SUP 12, the Board gets the Quarterly Pack, the CEO gets the Executive Summary, the Compliance Officer gets the SUP 12 Snapshot, and you rehearse on the FCA Dry-Run. When an AR's rating changes, the platform opens the intensified-monitoring plan SUP 12.6.13R requires and tracks it to a named owner. See it all in a live demo.
From Compliance Officers to principals, firms are replacing a spreadsheet of AR contacts with a scored, evidenced, board-reportable oversight programme.
The SUP 12 Health score is the single most defensible number we've ever put in front of our board. Before, AR oversight lived in a spreadsheet nobody could evidence. Now every point breaks down into a scored section with the register data behind it. Our last Board paper ran to three pages — and they asked better questions because the score actually meant something.
We got a SUP 12-cited, 14-chapter oversight report out of Otto in under a minute, built from our own onboarding, due-diligence and monitoring records. The risk-based monitoring flagged two ARs that had quietly drifted to Amber before anyone had written it down. A fraction of a consultant spend, doing the work of an annual review and a file-review exercise.
Everything you need to know about SUP 12 coverage, the Health score out of 100, Otto's 5-format report engine, risk-based AR monitoring, and how it sits inside RegTechPRO.