MHRA Guidance Note 6 – Notes for applicants and holders of a Wholesale Dealer’s Licence (WDA(H)) or Broker Registration was updated in November 2022 with some significant changes regarding Brexit.
However, in contradiction to the updated 2022 Green Guide, MHRA Guidance Note 6 still contains the following provision in section 9.7:
In the case of small companies, the Licensing Authority may accept the licence holder as the nominated RP. However, in larger companies, this is not desirable.
This is in direct opposition to the absence of this statement in the 2022 Green Guide (which has been written about in a previous blog post from this author and is included below for reference) and therefore clarification was sought and obtained from the MHRA.
Their response was that the updated guidance had been omitted from Guidance Note 6 in error and that a corrected version will be issued shortly.
Please be aware therefore that the MHRA are still expecting ALL businesses, whether large, medium or small, to have separation of the Licence Holder and RP and expect an update to the currently published Guidance Note 6 shortly.