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RE1 Blueprint Series · Task 15 of 16

Manage and Oversee the Representatives Appointed by a FSP

Task 13 covers what happens before someone is appointed. This task, across its 5 QCs, picks up immediately after — the ongoing oversight that continues for the entire length of a representative's career, not just at the moment they joined.

The 5 QCs, in full:
QC1 — Describe the on-going Fit and Proper requirements for representatives
QC2 — Verify record keeping for on-going Fit and Proper compliance of representatives is in place
QC3 — Implement a documented process ensuring representatives are competent to provide financial services
QC4 — Check that processes ensure representatives are progressing towards Fit and Proper requirements
QC5 — Describe the implications if a representative no longer meets the Fit and Proper requirements

QC1: Fit and Proper Never Stops at the Door

All five fit and proper pillars — honesty, competence, operational ability, financial soundness, and CPD — apply continuously to representatives, not only at the point of appointment. This is the ongoing companion to Task 13's pre-appointment check: fit and proper is assessed across a whole career, never satisfied once and then forgotten.

Real scenario: A KI appoints a representative and then has essentially no further contact with their work for a year. Even if nothing has gone visibly wrong, this is a gap — ongoing oversight means an active, continuing process, not a check performed once at the start and never repeated.

QC2: Records Must Mirror the Same Standard as the KI's Own

CPD evidence, competence records, and honesty checks for representatives must be documented and retrievable — exactly the same rigour a KI is expected to apply to their own fit and proper file under Task 4. A KI who cannot produce a representative's CPD evidence on request has a live compliance gap.

QC3: An Active System, Not Just a Filing Cabinet

Beyond record-keeping, QC3 requires an active system — regular competence checks, category-specific verification before a representative advises on a new product line, and a genuine mechanism for catching gaps before they become client-facing problems.

QC4: Tracking Progress, Not Just Waiting for a Deadline

For representatives still working toward outstanding requirements — typically RE5 within the 24-month DOFA window — this task requires visible, early tracking of progress.

Exam trap: Discovering at month 23 that a representative has made no progress at all toward their outstanding requirement. Early, ongoing tracking is the actual point of this obligation — a system that only checks in near the deadline has failed the "progress" half of the requirement, even if it technically monitors the date.

QC5: What Happens If Requirements Are No Longer Met

The implications scale with severity, and the exam expects you to distinguish between them rather than treat every shortfall the same way. A representative who falls behind on CPD might return to a period of supervision. One who loses a specific category's competence might have that category removed from their scope while the rest of their authorisation continues. A material or repeated failure moves into debarment territory entirely (Task 16). What the FSP cannot do, at any severity level, is simply let a non-compliant representative continue rendering services unsupervised while the situation is quietly monitored.

Quick Recap

Appointment Is the Start, Not the Finish Line

RE Mastery Hub's Task Quizzes test whether ongoing oversight was genuinely happening, not just whether the appointment itself was done correctly.

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