What you can say, and what you cannot

The test that covers almost every case

If you are describing a problem, you are an accountant. If you are prescribing a solution, you have become an unauthorised adviser.

That single distinction handles the overwhelming majority of conversations. Observing that £400,000 has sat in a company account for three years, earns nothing, and has no stated purpose is a statement about a client’s balance sheet. Suggesting they put £60,000 of it into a pension is a personal recommendation on a regulated product, and that requires permissions your firm does not hold.

What you may say

• What you can see in the accounts, the filings and the client’s position
• That an area looks worth proper attention from somebody qualified
• General factual information about how something works
• That you know a firm who does this, and would they like an introduction

What you must not say

• Name a product, a provider, a fund or a wrapper as the answer
• Recommend a contribution figure, a transfer or a withdrawal
• Advise on the merits of one option against another
• Tell a client what you would do in their position

That last one catches people out, because it feels like conversation rather than advice. A client asking “what would you do?” is asking for a personal recommendation, and answering it is the moment the perimeter gets crossed.

Four real examples

Instead of “You should put this year’s surplus into a pension.”
Say “There may be pension opportunities with this year’s surplus. That is exactly what our adviser colleague would look at. Shall I introduce you?”

Instead of “Those three old pensions should be combined into one.”
Say “Scattered old pensions are worth a proper review. Sometimes combining helps and sometimes it does not, and the adviser can tell you which.”

Instead of “You need £500,000 of life cover for that loan.”
Say “That loan is a real exposure with nothing behind it. Worth getting properly reviewed. Shall I set that up?”

Instead of “Cash is a terrible investment, markets will do better.”
Say “That cash is losing real value to inflation each year. What it should be doing instead is the adviser’s conversation.”

When the client pushes

They will push, because they trust you and you are in the room. “Just tell me what you think.” The correct professional answer is that it is a question for somebody authorised to answer it, and here is the introduction. That answer protects the client and your firm at the same time, and most clients recognise it as the right one.

Keeping a clean trail

Note what you said and when. Under the Altro arrangement every introduction records which words were used, and Equity & General reviews a sample each quarter. That is not bureaucracy for its own sake: showing that your team was given the approved wording is a weaker position than showing what they actually said.

What your firm does not take on

Introducing under this arrangement requires no FCA authorisation for your practice, no change to your professional indemnity cover and no compliance infrastructure. The advice, the suitability report and the regulatory responsibility sit with Equity & General, directly authorised under FCA number 474163.