Connect has recently updated its Risk Process following an internal review to ensure our approach to overseeing Appointed Representatives (ARs) remains clear, consistent and effective. The purpose of the Process is to support our ongoing oversight of ARs by identifying where additional guidance, monitoring or support may be required to help maintain the standards expected by the FCA across the network and deliver positive customer outcomes.
The process provides a transparent and structured framework, ensuring AR Principals and advisers understand the expectations, review timescales and the support available where improvements are required. It is intended to promote consistency, encourage early engagement and ensure firms receive the appropriate level of oversight based on their individual circumstances.
Monitor Tiers
Additional Risk Support Tiers
Headline Rules
Maximum time limits: Once on the formal Watchlist (Levels 1–3), a minimum of 3 months applies, but with a maximum of 3 months on any tier, and no more than 12 months in total across the watchlist Levels
Exit is by stepping down: Advisers must step back down through each tier with Risk Committee sign-off at every stage. Step-down requires at least 75% Green file reviews across a Risk Committee-set sample of 4–8 consecutive cases, no red files, and every amber finding remediated and evidenced.
Re-entry: Re-entering the formal Watchlist within 12 months of exit means entering one level higher than before.
Lender Warnings & Panel Removals
A formal lender warning or a lender withdrawing an application in suspicious circumstances is treated as a minimum Level 2 on the first event. A lender panel removal is treated as a minimum Level 3 on the first event, and following review, can result in termination from the Network. A lender declining to grant an agency is treated akin to a panel removal, subject to first confirming the reason with the lender.
Suspicious Case Report— Self-Reporting Protects You
Connect actively encourages advisers and their teams to raise a suspicious case report (SCR) for anything that raises a question, however minor. For example: suspect payslips, unclear evidence of deposit, recent second jobs etc.
When the case management, compliance team or lender reviews your case, if they deem it to be a suspicious case and it’s stopped from proceeding, this can trigger entry into the watch list. Flagging a concern yourself and asking for guidance, however, is not a Watchlist trigger, even if it’s recommended that the case then does not proceed Refer to the fraud indicator training on the learning management system for more information. If in doubt, you should raise it.
What You Should Do Now
Share this bulletin with every adviser and administrator in your firm.
Keep raising SCRs early and proactively, self-reporting remains the safest route.
Tell us straight away about any lender contact concerning quality, warnings, panel status or agency declines we would far rather hear it from you first.
If your firm is placed at any tier, engage fully with the notification letter, training and review timetable. The exit criteria and timescales are fixed, and engagement is the quickest way back to business as usual.
Any Questions? Contact the Compliance team or your Business Relationship Manager.
Best regards,
Shahrukh Malik
Compliance Director
For any questions or queries, contact the Compliance Team
Call : 01708 676110