Client Background

A regulated firm and tax planning specialist with structures that used second hand single premium bonds which it bought and sold as principal.

Business Issue

Business generation was primarily by way of third party introductions. The question arose, when was an introduction a regulated activity? The firm was concerned that introducers should not be seen as “making arrangements”. Introducers fell into two broad categories; unregulated and members of a designated professional body.


To navigate a way through the rules to ensure introducers could be paid without straying into regulated activities or breaching the rules of their designated professional body.


Complyport helped the firm with both a detailed opinion covering all likely permutations for introductions, taking into account FCA regulation and the designated body rules. The opinion included terms for when and how payments could be made. This was accompanied by a simplified version for use by the introducers.

Business Benefit

The firm clearly understood the boundaries between introducing and arranging. Introducers were given confidence, through the simplified opinion, that payments could be made, subject to following a process, and firms would not unwittingly stray into regulated activities.

Further Information

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