Here's what you need to know about Agent as Client.
Agent as Client
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Agent as Client (AAC) is where the DIM considers the adviser to be the client
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This is a model that has over the past few years been adopted and used by advisers when using the services of a Discretionary Investment Manager (DIMS) for client portfolios and particularly those using a Managed Portfolio Service (MPS).
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We strongly suggest our IFAs adopt an Agent-as-Client specific Terms of Agreement and ensure that you obtain the necessary permissions from your clients to act in this capacity. We are able to help with a template for this purpose.
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We also suggest that you work closely with your PI Provider to ensure cover is in place should a claim arise.
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Further information regarding Agent as Client (AAC) can be found in the following PFS Guides;
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Authority to act as agent
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It is the Adviser, as agent for the underlying client, that is giving the DIM authority to act.
Ongoing review
You have an obligation, both initially and ongoing, to assess the suitability of a discretionary service for the end investor and this should happen at least annually.
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This means that clients cannot enter a discretionary service without a suitability assessment being undertaken and you must assess ongoing suitability.
Due Diligence
We provide full support to assist you with meeting the FCA’s expectations.