The Financial Services Register answers a narrower question than most people bring to it. Reading it properly begins with noticing which question that is.
The entry is a licence record, and licence records are literal
Type a firm’s name into the Financial Services Register and what comes back looks like a verdict. It is not written as one. Every line is something the regulator granted, recorded or ended, phrased in the vocabulary of permissions rather than of customers, and the page has no opinion field because no opinion was collected.
The habit worth forming is to ask of each line what event put it there. Somebody applied and somebody decided, or a firm notified a change.
Matching the reference number on a website to the number on the entry is the check most readers have heard of, and it is the first thirty seconds, not the whole of it.
Permissions describe activities, and only the activities named
The permissions block is the substantive part. It sets out the regulated activities the firm may carry on, and against each one the investment types covered and the customer types it may serve. Retail, professional and eligible counterparty are three populations, and a firm permitted to deal with the last two has been permitted nothing in respect of you.
Further down sit the limitations and requirements, the most informative lines on the page and the least often opened. That is where a permission has been narrowed, a condition imposed or an activity fenced off.
A firm can hold a long list of activities and still be barred from the one you meant to use, and the summary view will not say so.
Four words can sit at the top of a page that looks the same either way
The status field decides what every other field means, which is an argument for reading it first. Authorised, registered, appointed representative and no longer authorised produce pages laid out identically, same typeface, same reference number format. Nothing in the design signals that you have changed category. A second property of that field catches careful readers as well as careless ones. The word records a present condition and carries no tenure with it. A firm authorised for nine years and a firm authorised a fortnight ago produce the same word in the same box. Whatever comfort it gives you, it is not giving you a track record.
| What the search returned |
What it may do with your money |
Whose permission it rests on |
The next field to open |
| Authorised |
Carry on the regulated activities listed, for the customer types listed |
Its own |
Whether the list covers the product you intend to buy |
| Registered |
Operate under a narrower regime than an investment permission grants |
A registration, which is not an authorisation |
Whether the activity you are buying sits inside it at all |
| Appointed representative |
Regulated business only within the scope its principal allows |
Its principal’s |
The principal’s entry, permissions and limitations |
| Trading name |
Nothing. A name is not a firm |
The firm the name is recorded against |
Which legal entity your contract will name |
| No longer authorised |
Nothing that needs the permission it used to hold |
A permission that has ended |
The date it ended, and what clients were told |
The five things a search of the Financial Services Register can return, and what each one entitles the firm in front of you to do.
Which company you would actually be arguing with
Consumer brands and legal entities part company early. Trading names are recorded against firms, so the brand on the app may belong to an entity you have never heard of, and a search on the brand alone can return the wrong firm or nothing at all. Neither outcome means what a hurried reader takes it to mean.
The reliable direction of travel is the other way round. Take the legal entity name from the client agreement or the foot of the website, search that, and confirm the brand appears among the trading names on the entry you reach. A minute longer, and it establishes which company you would be arguing with about money.
An appointed representative entry looks like a firm entry and behaves differently. The representative holds no permissions of its own. It conducts regulated business under a principal that has agreed to take responsibility for it, and the entry names that principal and the dates the appointment ran. The useful move is to stop reading and open the principal’s entry.
Two consequences are worth carrying away. The permission set governing what you can be sold belongs to a company whose name you may never see in the app. And an appointment can be terminated, changing what the firm in front of you may do while its website changes not at all.
A permission is a floor, and it was recorded on one afternoon
Everything on the entry records a threshold that was met. The firm satisfied the conditions, continues to satisfy them, and the regulator recorded that fact. Nothing on the page concerns spreads, execution quality, withdrawal times or whether anyone answers the support line, because none of it was ever collected. The register is a list of who may, never a list of who should, and reading it as the second is the commonest mistake made with the first.
A subtler misreading sits underneath that one. A permission set describes what a firm applied to be allowed to do, which makes it a record of intention that somebody once approved. A long list means an ambitious application, granted. It says nothing about whether the firm built any of it well, kept it staffed, or still cares about the corner you are about to use.
Permissions get varied, surrendered and cancelled on ordinary weekday afternoons, and no notification reaches whoever read the page last month. A check run in March describes March. The register updates perfectly well; the flaw is in the way people use it, since the check gets performed once, at the moment of most enthusiasm, and never again.
Two habits follow. Note the date you looked, because a check you cannot date is a check you cannot defend. And search by reference number rather than by name whenever you have one, since a firm’s brand, its trading names and occasionally its legal name can all change while the number stays put. Pepperstone’s UK entity is 684312 whatever the app is called this year, and a search on a number cannot quietly return the wrong company.
A funded account is opened at one entity, on one day
Everything the register settles is a question about standing, and what a reader wants settled is a question about conduct. Closing that gap needs somebody who dealt with the firm as a paying customer, which is the whole of the method behind The Investors Centre: open and fund live accounts with its own money to test UK trading platforms rather than compiling rankings from providers’ published fee schedules.
That work has a boundary of its own, in the same place. Funding an account records the terms one legal entity gave one retail customer on one date. A group holding permissions in several entities, or a firm revising terms between cohorts, can route the next applicant somewhere the tester never went. The register shows which entities exist to be routed to, the one direction in which it improves on the testing.
Write down four things before you close the tab
The reference number, the exact legal entity name, the status word, and the date you looked. Four fields, thirty seconds to copy, and they turn a check you half remember into one you can repeat and somebody else can repeat after you. A disagreement about what the entry said in August is settled by that note and nothing else you kept.
Then be exact about what you hold. A company exists, it may do a described set of things, and a named entity will be on the other side of the contract.
You have established nothing about whether it is any good at any of it. That is the right output for a licence record and a disappointing one for anybody hoping the state had done the choosing. …