Arranging & advice

Appointed representative

An appointed representative arranges loans exclusively for one represented party, with whom they have a written agreement. They are not the one who registers themselves: the firm notifies the register, and that firm is also liable for their activity. The represented party is sometimes a bank, but much more often an independent intermediary, that is, a network. This also determines which banks that person can show you.

Who registers them?

The represented party, not the representative themselves. It files an electronic notification with the Czech National Bank, which makes the registration without delay, within five working days at the latest.

It isn't automatic, though. The Czech National Bank will only register someone who isn't already in the register under another role. And only when the details given allow the people named to be identified in the state's basic registers.

Proof of competence and trustworthiness is held by the represented party. They keep it for the whole period of registration, and for at least a further five years after the registration ends. So if you ask who vetted the person sitting across from you, the answer is: the firm whose name appears against them in the register.

Why may they have only one network?

Because that's how the law sets it up. An appointed representative arranges loans exclusively for one represented party and must have a written agreement with them.

If two firms wanted the same person at once, the order of notification decides. The regulator only registers them for the earlier one, so dual membership doesn't exist in the register. You can see this in the open data: no company ID is repeated among appointed representatives. We've worked this out in the mortgage adviser market overview.

Which banks can they offer me?

The ones their network has. The offer isn't theirs, it belongs to the represented party.

When the represented party is a bank, they offer that one bank's products. When the represented party is an independent intermediary, they offer the banks that intermediary has agreements with, and this case is much more common on the market.

One specific question follows from this for your first meeting: what is the list of banks their represented party has agreements with. Networks usually publish their list of banks on their own website, so the answer can be checked. What matters further when comparing offers is covered in our mortgage comparison.

Who is liable for them if something goes wrong?

The represented party. The law says this directly for offences: liability for an offence committed in the course of an appointed representative's activity rests with the party they are registered under.

The same logic applies to damage. If an appointed representative commits a wrongful act against someone else while carrying out their activity, it is attributed to the independent intermediary they work under.

So an appointed representative is not the weaker option. A supervised firm with insurance is liable for their work, not an individual. What matters is something else: the list of banks their network has agreements with, and whether that person can explain to you why other banks dropped out of consideration.

What happens when they move to a different network?

Their authorisation ends and has to arise again. Once the agreement with the represented party ends, the register entry ends too.

The new network then files its own notification, and the Czech National Bank registers the same person again, with a new date the authorisation arose. Between the two there is a gap during which they may not arrange loans.

This creates a trap when reading the register. The date of registration does not measure how long that person has been in the profession. It measures how long they have been with this network. Someone who has moved through three networks in ten years has the date of the last one in the register, and the same applies across the whole market: a recent-looking entry doesn't necessarily mean a newcomer.

The same happens when the represented party itself ends. Once its authorisation ends, the registration of everyone working under it ends too.

How long does the registration last?

Until the end of the calendar year following the year of registration. It is extended by paying an administrative fee, always for a further twelve months, and the represented party files this on behalf of its people.

Anyone not extended drops out of the register. So the information ages quickly, and it's worth checking it at the moment you're handing over your documents to someone, not going by a business card from last year.

What should you ask them?

Three questions that cost nothing and reveal a lot.

  • Who are you registered under? You can find the represented party's name against their entry in the register.
  • Which banks does your network offer? "We compare the whole market" is not a list.
  • How much do you earn on my loan, and does it vary by bank? You are entitled by law to an answer; we cover this in the intermediary's commission entry.

What that person does for you and who pays them is summarised on the mortgage adviser page.

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