I. 3 Gearing up to trade – Checklist

Premises: Source appropriate space (consider transport links/parking etc). Shared office space facilities may be appropriate.

Lease/License to occupy: Access and segregation of area

Furniture and furnishings

Internet installation (it is worth considering that some broker platforms such as Acturis require a static IP, not simply a wi-fi network)


Joining a network and benefitting from the assistance that they can provide may be a route for some start-up brokers. Some networks will be able to provide help with insurer agency access, marketing and conduct issues.

Policies and documents to be written before trading:

  • Commercial and Regulatory Business Plan
  • A customer Terms of Business Agreement (TOBA)
  • Sales scripts to ensure sales calls are compliant
  • Letter templates – these are often built into a broker trading platform
  • Procedural policy documents and complaints procedures; The FCA sets out how to deal with complaints here.  Information is also available in the BIBA Compliance Manual details of which can be found here.The Financial Ombudsman Service produces some useful information about their involvement in complaints here.
  • Bribery & corruption policy – including: Financial crime policy covering Anti-Bribery, Sanctions, Anti-Money Laundering, Conflicts of Interests and Whistle-blowing. See Governance Section: B2 Financial Crime.
  • Data protection policy including GDPR. See Governance Section: B4 Data Protection.
  • On going processes regarding compliance with the Senior Managers & Certification Regime. See Governance Section B3 Compliance.
  • Other areas including, Health and safety, Information Technology, Business Continuity and Disaster Recovery, Card Payments, Training, Development and Qualifications, Newspaper and Copyright Licensing and Media Strategy. See Governance Section: B3 Compliance.