Accountants and mortgage introductions: can you take a fee?

01

Two sets of rules apply

The FCA rules decide whether the introduction itself is a regulated activity. Your professional body's rules decide what you must tell the client and whether you can keep what you are paid. Meeting one does not satisfy the other.

The FCA rules matter for regulated mortgage contracts, which include most second charges on a client's home. Business-purpose and many bridging loans fall outside them, but the ICAEW and ACCA commission rules still apply, because they cover any payment connected with referring a client.²⁴

02

The introducer exclusion

Article 33A excludes introductions to an authorised firm from the regulated activity of making arrangements with a view to a regulated mortgage contract. Two conditions apply. You must not receive any money paid by the client for the transaction, other than money payable to you on your own account. And before making the introduction you must tell the client about any group connection with the firm, any fee or commission you will receive for the introduction, and any other reward or advantage.¹

The FCA's guidance adds detail. Disclosing the method of calculation is enough, for example a percentage of the eventual loan. Indirect benefits count and should be disclosed too. The FCA would normally expect a written record of the disclosure, even when it was given orally.²

03

ICAEW members: consent to keep the commission

The ICAEW Code of Ethics, in force from 1 July 2026, says that if an accountant or an associate receives any fee, commission, payment or benefit in connection with referring a client, they must obtain explicit written consent to retain it, regardless of the amount.⁴

The Code explains why. Where an accountant acts as the client's agent or gives them professional advice, there is a fiduciary relationship, and the accountant has a legal obligation to obtain informed consent before keeping a third-party payment. ICAEW put it more plainly in 2024: without consent, it's the client's money.⁴⁵

04

Who you refer to

The ICAEW Code says an accountant must not make a referral, even with a disclaimer, if they know of a better alternative. A family connection or an automatic referral arrangement creates a clear threat to objectivity and must be disclosed to the client, along with any benefit you will receive.⁴

05

ACCA members

ACCA's rules require safeguards for any commission or fee received for introducing clients. Those include disclosing the arrangement to the client in writing and obtaining the client's advance agreement. ACCA also asks for special care that the advice is in the client's best interests.⁷

Where a firm is paid for regulated activity under ACCA's designated professional body arrangements, ACCA's factsheet says general consent is not enough. The client must be told the amount and their right to have it paid to them, must give informed consent in writing, and must be told at least annually what was received.⁸

06

Before you introduce a client

A short checklist drawn from the rules above. It is not a substitute for your professional body's guidance.

• Confirm the firm you're introducing to is FCA authorised for mortgages
• Tell the client, before the introduction, what you'll be paid or how it is calculated, and any group link
• Get the client's written consent to keep the payment, in the form your professional body requires
• Don't take any money from the client for the loan
• Pass on the facts. Don't recommend a lender, product or amount
• Keep a written record of what you disclosed and when

07

Introducing clients to Charles Frank

Charles Frank Finance is FCA authorised to advise on and arrange mortgages and second charges. We agree the commission arrangement with you in writing before you introduce a client, so you have what you need for the disclosure and the client's consent. We advise the client, keep you updated in your portal, and never cross-sell to your client.