Google and firms that advertise financial services

A little education for Lead Generators who are currently advertising their Lead Services on Google; it may lead to other online advertisers to take a similar stance. 

Google in July has made it mandatory that Firms that Advertise Financial Services must be either directly FCA Approved or be an Appointed Representative Firm of a Principal Firm, by 30th August 2021

A Firm must be able to be Directly Authorised by the FCA or have an exemption. The Exemption could be that they are an Appointed Representative Firm of another FCA Regulated Principal Firm. 

These Lead Companies are struggling to find a quick fix in the length of time to become directly authorised, so they are taking the potential route of becoming an Appointed Representative Firm of a Principal. They could also become Introducer Appointed Representatives to the Principals they introduce to.

Sturgeon Ventures  has been approached by numerous Lead Companies, in the last few weeks, however we do not have the appropriate permissions, these “Lead Provider Firms must find a Principal firm with the following types of Permissions.

Not all Principal Firms that offer Firms to use their Principal FCA License have the same permissions, and therefore it is worth checking the FCA Register see link below before making the enquiry. 

In looking for a Principal Firm check out the FCA Register with the name of the Principal and ensure they have these permissions to then contact them if they would take you on as an Appointed Representative Firm for your Lead Business. 

They must also ensure the Principal Firm under each of these activities can engage with the lead to the relevant potential customer, check the Customer Type on the Entry of the Principal Firm.

 What can the Company do: under Activities & Services?

  • Insurance
  • Mortgages
  • Home Finance
  • Pensions
  • Investments


Making Arrangements with a View to a Transaction.

Customer Type

  • Commercial
  • Professional
  • Retail (Investment)
  • Retail (Non-Investment Insurance)

Life Policy as an investment type


Making Arrangements with a View to a Transaction to include

And the Client Types must include

As above: 

  • Mortgages & Home Finance
    Permission Making Arrangements with a view to a transaction~
  • Pensions
    Making Arrangements with a View to a transaction

Other Activities

Drop down

The FCA is required to display some information related to certain non-regulated activities. Firms may do other business that is not regulated. You should check with the firm what business it carries out that isn’t regulated and what your protections may be.

Insurance Distribution

  • A firm that offers or sells insurance products and services.
  • This firm can undertake insurance distribution.

I would propose that these Lead Generators got multiple Introducer Appointed Representative Agreements with all the IFAs – Insurance Companies that they Introduce to

What is an introducer appointed representative?

SUP 12.2.8 G 21/03/2016 RP


An introducer appointed representative is an appointed representative appointed by a firm whose scope of appointment must, under SUP 12.5.7 R, be limited to:


effecting introductions to the firm or other members of the firm’s group; and


distributing non-real time financial promotions which relate to products or services available from or through the firm or other members of the firm’s group.


The permitted scope of appointment of an introducer appointed representative does not include in particular:


dealing in investments as agent; or


arranging (bringing about) deals in investments or arranging (bringing about) regulated mortgage contracts; or


assisting in the administration and performance of a contract of insurance; or


advising on investments, giving basic advice on a stakeholder product advising on a home finance transactionadvising on regulated credit agreements for the acquisition of land, or other activity that might reasonably lead a customer to believe that he had received basic advice or advice on investments or on home finance transactions or that the introducer appointed representative is permitted to give basic advice or give personal recommendations on investments or on home finance transactions.


An introducer appointed representative may have more than one principal, but will need a contract with each principal.


The approved persons regime does not apply to an introducer appointed representative (see SUP 10A.1.15 R).

SUP 12.2.9 G 30/06/2004 RP

To become an introducer appointed representative, a person must meet the conditions in the Act to become an appointed representative (see SUP 12.2.2 G).

SUP 12.2.10 G 30/06/2004 RP

All rules in SUP 12 apply in relation to introducer appointed representatives except for:


SUP 12.4.2 RSUP 12.4.5B R and SUP 12.4.5C, on the appointment of appointed representatives, which are replaced by SUP 12.4.6 R;


SUP 12.5.6A R on required contract terms, which is replaced by SUP 12.5.7 R; and


SUP 12.9.1 R (4) (Record keeping).

SUP 12.2.11 G 01/11/2007 RP

If an introducer appointed representative an individual in business on his own, then he will also be an introducer (see SUP 12.2.13 G). This has certain implications in COBS.


You can read more on this topic on the Money Marketing website.


For Educational and Discussion Purposes Only:  The information contained in this article has been derived from publicly available sources and is not intended as an offer or solicitation for the purchase or sale of any investment in any jurisdiction.  No advice is being offered nor recommendation given, and any examples are purely for illustrative purposes.