Agents, Representatives & Introducers
This guidance explains how licensed entities may use agents, representatives, or introducers, and clarifies accountability, permitted activities, and disclosure expectations.
Purpose of This Guidance
Many licensed entities engage third parties to support distribution or client introductions. This guidance sets out the boundaries within which such arrangements may operate.
Definitions
Agents, representatives, and introducers are third parties that act on behalf of, or in connection with, a licensed entity. Their role must be clearly defined and documented.
Permitted Activities
- Introducing prospective clients to the licensed entity
- Providing factual information approved by the licensee
- Marketing within defined and supervised parameters
Prohibited Activities
- Holding client funds or assets
- Making discretionary decisions
- Providing regulated services in their own name
- Presenting themselves as licensed by the Authority
Accountability and Oversight
Licensed entities remain fully responsible for the actions of their agents and introducers. Adequate oversight, training, and contractual controls must be in place.
Disclosure Requirements
Clients must be informed of the role of any intermediary and the identity of the licensed entity providing the regulated service.
Conclusion
Third-party arrangements can support growth, but they do not dilute regulatory responsibility. Licensees must ensure that all intermediary activity aligns with license scope and conduct standards.