21 Agent as client vs reliance on others An adviser firm recommending the use of a third-party discretionary management solution can set up the arrangements with the discretionary manager on the Agent as client (AAC) or Reliance on others (ROO) basis. See our separate guide on the structure of these arrangements which is available from the authors. The structure of these arrangements does not change with a firm’s classification as a manufacturer, distributor, or co-manufacturer. However, as part of their Consumer Duty implementation plan, each party will need to ensure that the structure of the arrangements meets the Consumer Duty requirements, particularly in terms of the Consumer Understanding outcome.
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