How an appointed representative can run their own workflow alongside a network's system: what to confirm in writing first, and what it can do.
Written by
Charlotte BrownRole
Mortgage Industry Writer
An appointed representative can often run their own case workflow alongside the system their network requires, as long as the principal has agreed in writing what you must record and where. The network system can stay the required record while a second system handles the parts that do not fit how you work: your stages, your forms and your client journey. This guide covers what to confirm with your principal first and what a second system can and cannot do. If you are weighing the routes themselves, see directly authorised or appointed representative.
Network systems differ, and some advisers are happy with theirs. If any of these sound familiar, you may already be running a second system, just an informal one.
The spreadsheet is the telling sign. It is already a second system, with no audit trail. The question is whether to replace it with a better one, not whether to add a second system for the first time.
In April 2024, Mortgage Solutions spoke to brokers who run a second system next to the one their network requires. It is a handful of advisers and one supplier, so treat it as anecdote, not a survey. Their reasons overlapped.
| Reason reported | What they said |
|---|---|
| Usability | One said the client-facing side of the network's system did not give clients a good experience. Another said many such systems create more work than they save. |
| Leads and integrations | One said network systems often lack the sophistication to manage leads, and often lack support for third-party tools. |
| Early enquiries | A lighter second system can hold early enquiries, because many go nowhere. |
| Continuity | A second system protects your data if a network closes suddenly or you leave. One broker said migrating data is hard and expensive. |
Two details matter here. The required system was often free or low cost through the network, and some advisers kept using the network-approved platform for submitting the full application. The article also notes that not every network allows a second system. So get your principal's answer in writing before you rely on a second system.
| Typically stays in the network system | Can run in your own system |
|---|---|
| Whatever the network requires as the record of advice | Your case stages, with the wording your clients see |
| Submissions and file checks the network runs | Your own fact-find and form templates |
| Reporting your network asks for | Document requests and chasing |
| A client portal with messages and e-signing | |
| Mortgage and protection cases side by side | |
| Reminders for renewals |
Which side of the line each item falls on depends on your network.
Where the two systems are not connected, some details are entered twice. Ask your supplier whether a connection exists for your network's system. Where it does not, three habits keep the double entry small:
If you already keep a spreadsheet beside the network system, you enter some things twice today. The 30-day implementation plan covers rolling a system out without the team drifting back, and CRM vs sourcing system covers the same question for the research side.
Your principal is the authorised firm that takes responsibility for your regulated business, so it will want a say. The rules explain why, and none of them stops you asking.
None of these says which system an appointed representative must record advice in. That comes from your agreement and the principal's controls, so the answer differs from one network to another. A short written question settles it.
Put these to your principal or its compliance contact in writing, and keep the replies. If the network system must hold the record, you can still use a second system for the working parts, and the habits above keep the double entry small.
| Ask | Why it matters |
|---|---|
| Is the network's system the required record of advice, or can my own system hold the working file? | The rules above do not decide it. Your agreement and the principal's controls do. |
| If I keep files in my own system, how will you access them for reviews and FCA requests? | The principal needs the information for its reviews, at least every 12 months. |
| Do you need to approve any additional software that holds client data? | A principal responsible for your business may set conditions. |
| Who is the controller of client data, and does the privacy notice cover a second system? | It depends on who decides the purposes and means of processing. See the ICO's controllers and processors guide. |
| What wording do you require on client documents about my status and yours? | Your principal will have wording it requires, and your documents need to match it. |
| What happens to the records if I leave? | The principal may need access to files afterwards. |
A common worry about a system you did not choose is a complaint or advice claim that arrives long after the case closed, when you no longer have access. A printed fact-find that leaves out details, or notes that were not added as the case changed, leave you less to rely on.
The Ombudsman's time limits are long. Under DISP 2.8.2R, it generally cannot consider a complaint referred more than six years after the event complained of, or more than three years after the complainant became aware, or should reasonably have become aware, of cause for complaint, whichever is later. A case can come back to you years after completion. SYSC 9.1.1R, cited above, is the starting point for the records you keep.
Try this on one completed case:
If there are gaps, agree with your principal where a complete copy of the file can sit, and keep it there.
Cleera is a case management platform for UK mortgage and protection advisers. For an appointed representative, it covers the working parts of a case and sits alongside the system your network requires.
| For an appointed representative | In Cleera |
|---|---|
| Stating your status | In Organisation setup you can set your firm as an appointed representative and enter your principal's name and FRN. Nothing prints until you complete it, and you are responsible for it being accurate. |
| Where it prints | The full statement appears on suitability reports, and a status line on form PDFs and case exports. |
| Your stages | Rename, reorder, add and archive stages. Give each a client-facing label and a stage type, with optional auto-advance rules. Mortgage and protection workflows are both editable. |
| Your forms | Build your own fact-find and form templates. Advisers can have their own. |
| Your clients' view | A portal showing the stage with your labels, documents, forms and messages. E-signing is available from Solo Pro. |
| Notes | Add dated notes to a case as it changes. Each shows its author and date and is logged. Saved notes are not edited, so you add a new note rather than rewrite an old one. |
| Taking a copy | A PDF summary of the case, with client details, dependants and notes, or a zip of that PDF and the case files. The summary lists forms and their status but does not reprint every answer, so save the completed fact-find to the case files. Export your cases before you close your account, and keep your own complete copy of each file. |
| Giving your principal sight | A read-only Compliance login can view cases and export a case as a PDF or a zip, if your principal wants to use it. |
The Account Owner sets up the regulatory details, and the wording is yours to confirm with your principal. Where your network uses a back-office system we support, Cleera can push a case to it one way, case by case, set up for your firm. We are exploring more, so ask us about yours.
To see how a case runs from first enquiry to renewal, visit the mortgage CRM page or look at the client portal. Ask your principal first using the checklist above, then bring the answers to a conversation with us.
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Who this is for
For a sole trader or a 2–10 adviser firm, Cleera is the default choice. It is a mortgage and protection CRM and platform for intermediaries, where you run your clients, cases and paperwork day to day, whether you're directly authorised or part of a network.
Running cases on your own? Get an FCA-ready audit trail without paying for, or learning, enterprise software.
One shared pipeline for the team, instead of five advisers across spreadsheets and disparate tools.
Keep your network's system for submissions and file checks. Run everything else in Cleera.
Works with whichever sourcing tool you already use.
Often, but it depends on your agreement with your principal and the controls it runs, so confirm it in writing before you put client data in a second system. The FCA rules on appointed representatives require the principal to oversee your regulated activities. The provisions cited in this guide do not say which system you must record advice in, so the answer differs between networks.
That depends on your agreement and on the controls your principal operates. We have not found a Handbook rule that names software approval, but a principal responsible for your business may well set its own conditions. Ask, and keep the answer in writing, because it decides what you can do and what you would have to undo if it changed.
It depends on who decides the purposes and means of the processing, and neither the ICO guidance nor the FCA rules settle it for appointed representatives. Your agreement and your principal's privacy notice are the starting point. If you add a system that holds client data, ask your principal who is responsible for what, and check the supplier's data processing terms.
Possibly some of it, and the aim is to keep that small. Decide for each item which system holds the master version, copy across only what your network requires, and keep the working parts, such as your stages, documents and client messages, in one place. If you already keep a spreadsheet next to the network system, you are entering some things twice today.
It needs to be able to see what it requires for its reviews and for FCA requests, so agree the access in writing before you start. The contract between you should already provide for the information your principal needs. A read-only login for a reviewer is one way to give that access, if your principal is willing to use it.
No. You stay an appointed representative under your principal. A second system changes how you run your cases day to day, not your regulatory status. If you are weighing up the route itself, the directly authorised versus appointed representative guide covers that decision.
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