An exclusion used in UK financial services practice where a person only introduces a
client to an FCA‑authorised firm that will arrange and/or advise on a
regulated mortgage contract, so the introducer is not treated as carrying on the regulated activity of arranging. It is set out in legislation: Article 33A of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (RAO).
The exclusion typically applies if the introducer limits their role to making introductions or passing basic contact/preliminary details, gives no
mortgage advice, does not negotiate or influence terms, and leaves all arranging/advising to the authorised firm. It is commonly relied on by estate agents, accountants, solicitors and other professional introducers referring clients to mortgage intermediaries, reducing the need for separate FCA authorisation or appointed representative status.
The position is consistent across England & Wales, Scotland and Northern Ireland under FSMA/RAO. There is no direct equivalent in Ireland; mortgage intermediation is regulated by the Central Bank of Ireland and the term “Article 33A exclusion” is not used in Irish legislation.
Related financial promotions must still comply with the UK financial promotion regime and rely on a separate exemption or approval where necessary.