Setting up Appointed Representatives

The Senior Managers and Certification Regime (“SM&CR”) potentially involves a number of complex relationships. By design, Corterum is a very flexible system – created this way so that it can handle these relationships. An example of some of the relationships that may exist would include:

1. Some staff members may need to access the Corterum system but may not be subject to the SM&CR (e.g. data processors who may be “Ancillary Staff”);

2. It may be necessary/desirable to maintain SM&CR or similar data about other individuals, but they may not require access to the Corterum system (e.g. staff working at Appointed Representatives);

3. Some staff members may work for multiple group companies (all of which are subject to the SM&CR) but perform different roles across different group companies; or

4. Despite the fact that ex-members of staff may no longer require access to the Corterum system, it is necessary to maintain information about those ex-members of staff (e.g. for the purposes of responding to a regulatory reference request).

At first, it may appear that Corterum is complex to set up – particularly with respect to a firm which has a simple corporate structure. In truth, there is always a trade-off between flexibility and complexity. However, in reality, it is this flexibility which gives the platform its power.

Corterum allows admin users to set up and track individuals within Appointed Representatives.

However, please be aware this is will incur a charge for each person created (broadly, Corterum charges by reference to the number of individuals about whom information is actively being stored).

In order to see how this is done, let’s consider the following example:

1. You are an administrative user of Corterum.

2. You work at Megacorp (the primary regulated entity which is subject to the SM&CR).

3. You wish to set up Joe Bloggs within the Corterum system.

4. Joe Bloggs works for ABC Appointed Reps Ltd (an Appointed Representative of Megacorp).

Go to Administration>Entities>’Plus Sign’>Business.

Here you can create a new “business entity” for ABC Appointed Reps Ltd. Creating the “business” entity will allow us to (a) store information pertaining to ABC Appointed Reps Ltd, and (b) link individuals (in our example, Joe Bloggs) to ABC Appointed Reps Ltd.

Fill in the required details and click the “Appointed Representatives” checkbox.

A “Company” within Corterum should be thought of as the entity that is primarily subject to the SM&CR. It is possible that you have more than one group company that is subject to the SM&CR. Corterum enables users to store data about all such entities by creating them as separate “Companies” within Corterum.

When users subscribe to Corterum, the out-of-the-box installation comes with one default “Company”. In our example, this would be Megacorp.

In order to see information about ABC Appointed Reps Ltd in the context of the Megacorp company, the two must be linked together. In order to do this:

1. Go to Administration>Entities

2. Click on the ellipsis next to “ABC Appointed Reps Ltd”.

3. Select “Link to Companies”.

4. Link “ABC Appointed Reps Ltd” to the “Megacorp” company.

Next, we need to create a person entity for Joe Bloggs. Joe is the individual working within ABC Appointed Reps Ltd about whom we wish to store certain regulatory data. In order to do this:

1. Go to Administration>Entities>’Plus sign’>Person entity.

2. Fill in the details for Joe Bloggs.

For example, if you go to Workbench>Datasets>Staff>Staff Information>’Plus sign’ – you will be able to create a “Staff Information” form for Joe Bloggs. You will be able to select Joe Blogg’s name in the “Name” Field and select “ABC Appointed Reps Ltd” from the “Employer” field. In this way, it is possible to stay abreast of the fact that Joe Bloggs works for ABC Appointed Reps Ltd (and not Megacorp).

Remember to check the “Appointed Representative?” box for Joe Bloggs.

You may or may not want to create a user account for Joe Bloggs. It depends on whether you want Joe Bloggs to have access to the Corterum system. Please see The link between users and entities for more information on this aspect of Corterum.