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.
Dopple is a trading name of Social Money Limited who hold credit broking permissions. If your firm is not already authorised by the FCA and you only intend to introduce your customers to Dopple’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 Social Money Limited.
​
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 Social Money Limited T/A Dopple.
Advertising finance available through Dopple’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 Dopple technology 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 Social Money Limited (Dopple) you understand that Social Money Limited 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 Social Money Limited (Dopple) requirements, which are based on the FCA’s rules and regulations, Social Money Limited (Dopple) 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 Social Money Limited (Dopple) needs you to meet, and that you are ready and organised to meet those requirements. Dopple 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 Dopple need so much information about my firm?
​
Social Money Limited (Dopple) 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, Social Money Limited (Dopple) must be satisfied that your firm is capable of meeting the necessary requirements.
Social Money Limited (Dopple) 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 Social Money Limited (Dopple) did not ask for this information, it would not be able to demonstrate that it has met its regulatory obligations and so these requests are mandatory.
​
What is the process to become an IAR?
​
Once you have indicated to Dopple that you would like to become an IAR, you will receive several information requests, including:
Merchant/Retailer Approval Form – to capture key information about your firm, your products, customers, 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.
Policies and procedures – we need to see that you have suitable policies and procedures in place to treat your customers fairly and achieve good outcomes for them. As a minimum, we will ask you to confirm that you have policies on vulnerable customers, complaint handling, privacy, cancellation and returns. 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.
Under FCA rules, we are required to notify the FCA of our intention to appoint you as an IAR at least 30 days before you are permitted to perform any regulated activity. During this time, we will work with you to prepare your integration but you must not place any content in relation to Dopple finance options on your website.
The FCA will process our notification and your firm will appear on the Financial Services Register as an IAR, with Social Money Limited (Dopple) as your Principal Firm. You will then need to integrate Dopple’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 – Autify.
Once trading, you will need to provide us with some regular reporting and information, which will be set out in the IAR Agreement. This is compulsory so that Social Money Limited (Dopple) can continue to meet its obligations as your Principal firm, and submit its legally required reporting to the FCA.
​
What happens if my firm doesn’t comply with Dopple’s requirements?
​
As an IAR, if you fail to meet Social Money Limited (Dopple) requirements, we will initially attempt to work with you to correct any issues or make any necessary improvements. However, if your firm remains not compliant, Social Money Limited (Dopple) 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 Dopple’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 Social Money Limited (Dopple).
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. Social Money Limited (Dopple) will need to be informed of this course of action in advance.
