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Introducer Appointed Representatives

Why do I need to be appointed as an Introducer Appointed representative (“IAR”)?

Introducing your customers to lenders, who will provide them with credit to help finance their purchases is known as credit broking. Credit broking in the UK is a regulated activity, which means that the Financial Conduct Authority (“FCA”) supervises the activity.

In order to perform any regulated activity in the UK, a firm must be authorised to do so by the FCA and hold relevant FCA permissions for their activity.

Deko is an FCA authorised credit broker and holds the required credit broking permissions. If your firm is not already authorised by the FCA and you only intend to introduce your customers to Deko’s credit broking technology, we are able to appoint you as an IAR. This means that you will be able to perform credit broking activity under Deko’s FCA permissions.

What is an Introducer Appointed Representative (“IAR”)?

An IAR is a non-FCA authorised firm that has been appointed by an FCA authorised firm to perform limited regulated activity. The activity is limited only to:

  • Introducing your customers to Deko, or another company in Deko’s Group (i.e. NewDay)
  • Advertising finance available through Deko’s technology in a non-interactive dialogue (this is known as a non-real time financial promotion)

What does being an IAR mean for merchants?

As an IAR, you will be able to introduce your customers to Deko’s technology or to NewDay for their credit needs. You will not need to apply to the FCA for authorisation to perform this activity if you are an IAR.

Being an IAR for Deko means that Deko is your “Principal Firm” and is accountable for all regulated activity performed by you and for the outcomes you achieve for customers. Therefore, if you do not comply with Deko’s requirements, which are based on the FCA’s rules and regulations, Deko will be responsible and could be fined and publicly censured by the FCA.

This is why it is critical that you are aware of the requirements that Deko needs you to meet, and that you are ready and organised to meet those requirements.

Deko has prepared some handy information to help you understand the requirements for your website, sales processes, advertising and reporting. Our Business Development Team and our Account Managers are on hand to provide further support if you need it.

Why does Deko need so much information about my firm?

Deko will be agreeing to take full responsibility for the conduct of your firm and its employees in respect of credit broking activity. Given the serious consequences of misconduct and non-compliance, Deko must be satisfied that your firm is capable of meeting the necessary requirements.

Deko has regulatory obligations to ensure that any IAR it appoints is ready, willing and organised to comply with the relevant requirements, and that the Directors, Owners or other Senior Management of the IAR are reputable individuals.

If Deko did not ask for this information, it would not be able to demonstrate that it has met its regulatory obligations and so these information requests are mandatory.

What is the process to become an IAR?

Once you have indicated to Deko that you would like to become an IAR, you will receive several information requests, including:

  • Merchant Approval Form - to capture key information about your firm, its sales and financial history
  • AML/ID requests - we ask for this so that we can perform important anti-money laundering checks on your firm and its Directors and Owners
  • IAR Questionnaire - the information requested here helps us to understand and demonstrate that your firm is ready and organised to comply with the necessary requirements.

You will be asked to enter into an IAR Agreement, which stipulates the important terms of your appointment as an IAR.

The Lender will need to approve that they are happy to offer their credit products on your website.

You will then need to integrate Deko’s technology with your website - we have some useful guides on how to do this and you may receive support from our specialist integration provider - ImegaMedia.

Once all of this is completed, we will countersign the IAR agreement and we will then notify the FCA of your appointment. The FCA will process our notification and your firm will appear on the Financial Services Register as an IAR, with Deko as your Principal Firm.

You will be able to commence trading with Deko’s technology from the date we countersign the IAR Agreement. Once trading, you will need to provide us with some regular reporting and information, which will be set out in the IAR Agreement.

What happens if my firm doesn’t comply with Deko’s requirements?

If an IAR fails to meet Deko’s requirements, we will initially attempt to work with you to correct any issues or make any necessary improvements. However, if your firm remains non-compliant, Deko may need to suspend or even terminate your IAR appointment. If the IAR appointment is suspended or terminated, you will need to immediately stop introducing your customers to Deko’s technology and will be unable to offer finance options to your customers.

What if I want to offer customers finance from other lenders?

As an IAR, your permitted activity is limited only to introducing customers to Deko or to NewDay, which is part of the same group of companies as Deko.

If you want to introduce customers to other lenders directly, you will either need to be appointed as an IAR for the other lender(s) or apply to the FCA for your own authorisation.