The FCA’s enhanced AR regime demands evidence of oversight — run appointment-to-termination supervision of every appointed representative from one platform.
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Every AR its own segregated record
Appointment → oversight → notifications
Per-AR scorecard PDFs, one click
Since December 2022, the enhanced AR regime has put principal firms under direct supervisory scrutiny — and the burden of proof sits with you.
The December 2022 rules added annual self-assessments, advance notification of new appointments and yearly AR data reporting. The FCA reads that data — and follows up.
Are they following your procedures? Were their promotions approved before they ran? Without a live view of every AR, you find out when something has already gone wrong.
Chasing accounts, PI insurance, references and FCA Register checks — then doing it all again at every annual review. Each new AR multiplies the burden.
Appointment requirements (SUP 12.4), contract terms (SUP 12.5) and the annual self-assessment (SUP 12.6A) each demand their own evidence. Keeping all three current across a network is a full-time role.
You're on the hook for their mistakes. If an AR causes customer harm, it's your FRN at risk. The liability keeps you awake at night.
You started with Excel, but now it's a mess of files, versions and manual processes. Every new AR makes the problem worse.
Appointment, oversight, notification and termination for every appointed representative — finished with a per-AR PDF scorecard your board can read in five minutes.
Appointment due diligence through to termination, with SMF sign-off recorded at every approval step (SUP 12.4.6AR).
Intensified monitoring plans for higher-risk ARs, evidenced against SUP 12.6.13R — supervision that matches the risk, not a flat rota.
Financial promotions and attestations from every AR land in one pending-approvals queue — approve or reject, every decision logged.
Structured, chapter-by-chapter evidence for the annual self-assessment the enhanced regime requires (SUP 12.6A.1R).
The principal’s 30-second view of the whole network. A SUP 12 Health score out of 100, RAG-rated, with live KPI tiles — Active ARs, Approved Persons, open Issues and Attestation status — a section-by-section heatmap and an AR risk-distribution bar.
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.
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.
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.
Your ARs’ senior people are your regulatory risk. Assess, certify and evidence them to the same standard as your own staff.
The 55-question FCA Form A Section 5 assessment (FIT 1.3) for approved persons across the network, with a RAG declaration summary.
Annual Certificates of Competence for certified staff, generated and filed per person — renewal dates tracked so nothing lapses.
Conduct-rules training and CPD hours tracked per person against the FCA’s 35-hour benchmark, with a full activity log.
DBS checks, references, ID verification and credit checks per person — each with a status and the evidence file attached.
The regulated population on one screen. KPI tiles for Total People, Senior Managers, Certified Persons, F&P Outstanding and DD Outstanding, over a full People Records register — name, job title, role type and email. Click any row to open the record.
The full FCA Form A Section 5 Fit & Proper assessment, live: a five-node wizard across Criminal · Civil · Business · Regulatory · Other matters, with a RAG Declaration Summary and a one-click Export F&P Certificate.
Continuing Professional Development, evidenced. Structured and unstructured CPD hours against an annual target, a completion ring and a full activity log — course, type, hours and date — so every certified person across the network stays current and provable.
The FCA judges your own house as hard as your ARs’. Run the firm’s monitoring plan, registers and attestations from the same platform your network reports into.
Monitoring templates across 74 categories — including a dedicated AR-network chapter — so the programme starts complete, not blank.
Periodic attestations with a second-pair-of-eyes approval flow — every submission and decision timestamped.
Complaints, breaches, conflicts and financial promotions in one evidence trail — filter, search and export the lot.
Every task on a drag-drop kanban board and a five-year regulatory calendar — owners, due dates and time buckets at a glance.
The head-of-compliance landing surface. Live KPI tiles for open, closed and overdue tasks, completion and approval rates, an overall Health Score, RAG summary and monthly trends — every tile a one-click drill-down to the records underneath.
Every event your firm has to record, in one tracker. Complaints, Breaches, Gifts & Entertainment, Conflicts and Financial Promotions — status chips, named owners, due dates and the same maker-checker approval workflow throughout.
Every task type on one board — monitoring activities, attestations, registers and custom forms — organised by status or time bucket, with drag-drop between columns and the approval workflow flowing through every card.
Otto’s headline deliverable: a 12-section Annual Compliance Monitoring Report drafted from your live data — coverage, execution, attestations, registers, findings and remediation — generated section by section, edited in place, exported.
Otto is the platform’s built-in compliance advisor, grounded in 150+ expert-authored documents. She reads your live AR records — not a generic handbook summary — and drafts the reports the regulator expects to see.
All 14 chapters of your SUP 12 posture, drafted per-AR or network-wide — every finding traced to a live record.
One to two pages for the CEO and Exec Committee: where the network stands, the risks that matter, and what needs a decision.
Every AR's report rolled up into one board pack — network health, RAG distribution and the ARs to address first.
A 12-question mock supervisory interview built from your own network data — rehearse the hard questions before the FCA asks them.
AI drafts, humans decide — nothing is auto-submitted, and every fact traces to your live network data.
Three ways to run a network. Only one produces evidence the FCA can inspect — on the day they ask for it.
What a principal firm running an AR network wants to know about platform-grade SUP 12 oversight.
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