MEMA Scope · Assessment
Do mortgage appointed representatives need FCA authorisation?
A smaller firm advises on or arranges mortgages as an appointed representative of an authorised network or principal firm. Review the initial view below and answer a few questions to refine it.
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Potential regulated activity identified
You may be able to carry on mortgage activity as an appointed representative
An appointed representative relies on its principal’s permission and the principal accepts responsibility for what it does within the agreement.
Route to consider: Appointed representative of an authorised principal, or direct authorisation
Why this was flagged
- 1Mortgage advice and arranging are regulated activities even when done for a principal.
- 2The AR regime lets an authorised principal take responsibility for the AR’s regulated activities.
Questions still to resolve
Answer to refine the view. The result updates as you go.
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Does your principal hold permission for every mortgage activity you will carry on?
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Do you want to use your own name and brand as the main contracting party with customers?
Regulatory basis to examine
Your next steps
- 1Agree the scope of activities with the principal in writing
- 2Check how the principal supervises and trains its appointed representatives
- 3Compare the AR route with your own authorisation
- 4Understand what happens to your client book if the arrangement ends
Where applications for this model most often fall short
- A written AR agreement with a clear scope of permitted activities
- Evidence of your qualifications and competence
- Clarity on who owns the client relationship and data
This is an initial indication from published FCA material, not an FCA determination or legal advice.
If authorisation is required, check the firm’s governance, policies, resources and application preparedness.
MEMA Scope gives an initial view from published FCA material. It is not legal advice or an FCA determination. Automatic matching and typed questions use AI only to choose a profile and to answer from vetted guidance; the assessment itself is never written by AI.
About this business model
A smaller firm advises on or arranges mortgages as an appointed representative of an authorised network or principal firm.
An appointed representative relies on its principal’s permission and the principal accepts responsibility for what it does within the agreement.
This page gives an initial view from published FCA and legislation sources. It is not an FCA determination or legal advice. Not your business model? Describe your business in MEMA Scope.
Appointed representative of a mortgage network: frequently asked questions
Can I advise on mortgages as an appointed representative?
Yes, in principle. An appointed representative may carry on regulated activities that its principal is authorised for and has accepted responsibility for, subject to the principal’s agreement and oversight.
Does an appointed representative need its own FCA permission?
Not for activities covered by the AR exemption, but the principal remains responsible and the arrangement must meet FCA rules in SUP 12.
What could change the answer for mortgage appointed representatives?
An appointed representative relies on its principal’s permission and the principal accepts responsibility for what it does within the agreement. It can change depending on the answers to questions such as: Does your principal hold permission for every mortgage activity you will carry on? Do you want to use your own name and brand as the main contracting party with customers?
Which FCA rules should mortgage appointed representatives look at first?
Start with: Exemption of appointed representatives; SUP 12: appointed representatives; FCA: appointed representatives and principals; PERG 4: mortgage activities. This is an initial view from published FCA material, not an FCA determination.
What are the first steps for mortgage appointed representatives?
Agree the scope of activities with the principal in writing. Check how the principal supervises and trains its appointed representatives. Compare the AR route with your own authorisation. Understand what happens to your client book if the arrangement ends.
Businesses we check
MEMA Scope covers 32 common business models. Each page explains whether that kind of business may need FCA authorisation, the rules to look at and the routes to consider.
Consumer credit
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- Do debt management and debt advice firms need FCA authorisation?
- Do credit lead generators and comparison sites need FCA authorisation?
- Do rent-to-own and vehicle leasing providers need FCA authorisation?
- Do credit brokers introducing customers to lenders need FCA authorisation?
Payments and e-money
- Do payments apps and payment processors need FCA authorisation?
- Do small payment institutions need FCA authorisation?
- Do e-money issuers and digital wallets need FCA authorisation?
- Do agents of payment institutions need FCA authorisation?
- Do open banking providers need FCA authorisation?
- Do money transfer and remittance businesses need FCA authorisation?
- Do marketplaces handling payments need FCA authorisation?
Insurance
Investments and wealth
- Do financial advisers need FCA authorisation?
- Do discretionary investment managers need FCA authorisation?
- Do investment platforms and wealth-tech firms need FCA authorisation?
- Do crowdfunding and peer-to-peer lending platforms need FCA authorisation?
- Do corporate finance boutiques need FCA authorisation?
Other regulated activities
- Do claims management companies need FCA authorisation?
- Do funeral plan providers and sellers need FCA authorisation?
- Do introducers and referral partners need FCA authorisation?
- Do international firms entering the UK need FCA authorisation?
- Do accountants and solicitors giving financial advice need FCA authorisation?
Want a consultant to look at your facts?
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