Commentary

A7.214 More than one promoter or client

Administration and compliance

A7.214 More than one promoter or client

A7.214 More than one promoter or client

More than one promoter

It is highly likely that there will be a number of parties falling within the definition of a promoter in relation to a scheme, and there can be confusion where there are both promoters and introducers. Those involved should first determine what position they take in the scheme for DOTAS reporting purposes. An example of multiple parties would be where firm A designs a scheme, firm B markets the scheme, and firm C actually implements the scheme. All of these would be promoters (see A7.210).Two of the parties will

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