Most of you can probably recite the legal definition of “advice” and “intermediary services” off by heart, having studied for the REs, but how many know how to interpret it correctly?
The FSB published a document on its website titled “Guidance Note: Intermediary Services and Representatives” which discusses the practical application of the definitions of advice, intermediary services and administrative functions in detail. There is also an interesting section dealing with how things should operate in the motor business which many of our readers in that industry will find interesting reading.
This information may also be of value to those who were unable to pass the REs in time.
Terminating the services of such a person is not the only option. While many who applied for an extension can continue working, there will come a time when you have to take action.
You can consider changing their job description to keep them employed, but only in an administrative capacity until such time as they manage to write the exam successfully. Such a person should obviously also be removed from the Rep register.
Please note that this can never be used as a front for people to continue working as representatives. Such action could result in the FSP’s licence being withdrawn.
Please make time to read this document, even if just to ensure that some of the functions performed by your admin staff are not, in fact, intermediary services.