Your FCA permissions boundary: what a broker can and can't advise on
Clarity about your permissions is what lets you refer confidently. This is a practical map of where a mortgage broker's advising authority ends and where the introducer role begins.
Confident referrals start with knowing exactly where your permissions end. Here is a plain-English map of the broker's boundary and the introducer role beyond it.
Why the boundary is an asset, not a limit
Brokers sometimes treat their permissions as a wall that keeps them out of profitable conversations. Seen differently, the boundary is what makes referral income possible in the first place. If you could advise on everything, there would be nothing to refer. Because your permissions are defined and finite, everything beyond them is a potential introduction to a specialist, and a potential share of the resulting fee.
The key to using that boundary well is knowing precisely where it sits. Vagueness leads to two failures. Either you stray across the line and give advice you are not authorised for, which is a compliance problem. Or you play so safe that you never even mention adjacent needs, which is a lost-value problem. A clear map lets you avoid both, staying firmly compliant while still capturing every referral the boundary creates.
What a mortgage and protection broker can advise on
Your core authorised activity is advising on and arranging regulated mortgage contracts. Within your permissions you also typically advise on and arrange protection products such as life cover, critical illness cover, and income protection, subject to the exact scope of your authorisation. This is real, valuable advice work, and it is entirely yours to do.
Within this space you can recommend specific products, assess suitability, and take responsibility for the advice. You know this territory. The point of mapping the boundary is not to second-guess your core work, but to be equally clear about where that work stops.
What sits outside your permissions
A range of common client needs fall outside a standard mortgage and protection permission set. Advising on any of these is regulated activity you are not authorised for unless you hold the specific permissions.
- Pensions. Contributions, transfers, consolidation, drawdown, and retirement planning.
- Investments. ISAs, general investment accounts, and packaged investment products.
- Wills and estate planning. Wills, trusts, lasting powers of attorney, and inheritance planning, which also involve legal permissions beyond financial regulation.
- Wider tax and financial planning. Advice on how a client should structure their overall finances.
Recognising a need in any of these areas is fine and useful. Advising on it is not something you can do. That single distinction is the whole game.
The difference between advising and introducing
The line that keeps you safe runs between advising and introducing. Advising means assessing a client's circumstances and recommending a course of action in a regulated area. Introducing means recognising that a client needs regulated advice and connecting them with someone authorised to give it, without expressing a view on what they should do.
In practice, introducing sounds like this: this is outside what I am authorised to advise on, but I work with vetted, regulated advice firms who specialise in it, and I can introduce you. Notice what that sentence does not do. It does not say whether the client should transfer their pension, invest their money, or set up a trust. It simply routes them to someone who can advise on those questions properly. Stay on the introducing side of the line and you remain compliant while still capturing the value of the referral.
How a referral network operationalises the boundary
Knowing the boundary is one thing. Acting on it profitably and compliantly is another. A referral network exists to turn the map into a working process. Through SmartPeer, the needs that fall outside your permissions become structured introductions to vetted, regulated advice firms that hold the relevant authorisations. They advise. You remain the introducer, and you earn a member share of the resulting fee, typically around 60 to 70 percent. SmartPeer introduces; it never advises, and the model is built precisely around the introducer role rather than around you giving advice you cannot give.
The result is that your permissions boundary stops being a place where value leaks away and becomes the place where referral income is generated. Every client need on the far side of the line is a specialist introduction waiting to happen. Understanding exactly where your authority ends is not a constraint on your business. It is the foundation of a second income stream, built entirely on being the trusted professional who knows what they cannot do and knows exactly who to call instead.
The referrals you already make — tracked, evidenced and paid
Free to join. Client consent captured online, a disclosure letter generated for every referral, and a statement that reconciles to the penny — with your firm keeping the majority share of every introducer fee.
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