How does the FCA impose the Conduct of Business Rules (COBs) on appointed representatives?

The Conduct of Business Rules (COBs) are a set of regulations established by the Financial Conduct Authority (FCA) to ensure that businesses operate in a manner that is fair and transparent to consumers. When it comes to appointed representatives, these rules are imposed primarily on the principal firm that appoints them.

The principal firm has the responsibility to ensure that its appointed representatives comply with the COBs. This obligation means that the principal firm must supervise the activities of its representatives, provide training and guidance as necessary, and monitor compliance with the regulations to mitigate any risk of misconduct. This framework ensures that consumer protections are upheld even when services are provided through an agent or representative.

While other enforcement actions or methods, such as audits or warning letters, may play a role in broader compliance strategies, the primary mechanism by which the FCA enforces COBs in the context of appointed representatives is through the obligations placed on the principal firm to maintain oversight and ensure adherence to the rules. This system creates an accountability structure, ensuring that the principal is actively engaged in overseeing the conduct of its representatives.