The RMAR – your regulatory shop window

We asked Rick Double, Senior Compliance Consultant at compliance experts UKGI to give us his thoughts on Retail Mediation Activities Return (RMAR) and what brokers need to think about when submitting their returns.  This is what he told us:

"As compliance consultants, we’re often asked: “Is it likely we’ll get a visit from the FCA?”  If you’re a small to medium sized broker, the answer to that question is: “Probably not.” 

The same applies to telephone calls; it’s not part of the FCA’s way of doing things simply to pick up the phone and talk to regulated firms. 

That said, it would be naïve to assume you’ve fallen off the FCA radar. 

So how might you come to their attention? 

You might be selected to take part in a thematic review; you’ll be well aware of the FCA’s ongoing interest in general insurance. 

You’ll have received financial resilience questionnaires during Covid and you should all be aware of the September 2020 ‘Dear CEO’ letter to personal and commercial lines intermediaries covering several hot topics:

I think of ‘Dear CEO’ letters as ‘Listen up!’ letters; you ignore them at your peril.

If you’re still thinking that FCA contact with and supervision of your business is distant, think again, because twice a year, four times a year for bigger intermediaries, you submit your RMAR. In other words, at least twice a year, you send a large amount of information to the FCA, personal to your business, for the regulator to evaluate. 

These days, we think of our websites as online shop windows; think of your RMAR as your regulatory shop window. What impression does it give to the FCA? Does it give them confidence in your business?

The golden rules are to take your time when completing RMARs; get them right; and submit them on time. 

In particular, make sure that the client money section (section C) is accurate. Yes, there is an element of cross-validation in the RMAR, but the client money section is a prime area where incorrect answers can be entered, will stand out if they’re wrong and may prompt a question from the FCA. 

The question will be in the form of an e-mail which you need to answer quickly and persuasively. If you don’t, that’s when the FCA might pick up the phone; and that’s when ‘FCA creep’ as I call it can happen. The conversation starts off with client money but tends to creep into other areas. A conversation is a very effective way of the FCA assessing your grasp of the rules."

If you’re confident with your RMARs, well done! If you’re unsure of anything, you can get in touch with us at UKGI on 01925 767893* or email

In the meantime, we hope our short video will help to answer some of your questions.

* calls charged at standard network rates.