Email signatures after a merger or tenant migration
Two companies, two brands and often two Microsoft 365 tenants. How to handle email signatures after a merger, from day one to the tenant move.
What must an accountant's or financial adviser's email signature include? A firm authorised by the Financial Conduct Authority must take reasonable care that its letters to retail clients, email included, carry its statutory status disclosure. An ICAEW firm that mentions its audit registration must use the Institute's fixed wording. And a firm that is a company or LLP has the company law disclosures as well. This guide puts the three together.
GEN 4.3 of the FCA Handbook requires a firm to take reasonable care that every letter, or electronic equivalent, that it or its employees send to a retail client in connection with a regulated activity includes the statutory status disclosure. Email is covered; text messages, business cards and compliment slips used as such are not.
For a UK firm that is not authorised by the Prudential Regulation Authority, the disclosure is:
Authorised and regulated by the Financial Conduct Authority
A PRA-authorised firm uses the longer form that names both regulators. Either way, the Handbook asks for the regulator's full name rather than "FCA" or "PRA". You may also want to add your Financial Services Register number after it, so a client can look the firm up.
ICAEW's helpsheet on practice names and letterheads sets out how a firm may describe its registrations. A firm registered for audit may use "Registered Auditors", "Statutory Auditors" or "Registered to carry on audit work in the UK by the Institute of Chartered Accountants in England and Wales", and must not vary the wording. There is no requirement to put that description on the letterhead at all; the rule is that if you use it, you use it exactly.
A firm licensed by ICAEW for a range of investment business activities has a fixed wording for that too, if it chooses to include one. Check the helpsheet for the current form, and do not improvise a shorter version for the footer.
Most practices are limited companies or LLPs, so their emails also need the registered name, registered number, registered office address and the part of the UK where they are registered. Our guide to UK email footer legal requirements covers those, including the rule that a footer naming one director must name them all.
The awkward case is common in this sector: an accountancy practice with a separate wealth management company, or an advice firm that is an appointed representative of a network. Each entity has its own registered details and its own regulatory wording, and a client email from the wrong entity's footer is a compliance problem, not a design one.
The answer is one template per entity, each with its own fixed wording, and a rule that picks the right one for each sender. In Footer365 a rule can target people by Email domain, Department, Job title or Group members, so the wealth team's domain or group gets the wealth company's footer automatically. Rules are checked from the top and the first match wins, so put the narrower ones above any rule for everyone. Our guide to targeting a rule by department, group or domain explains each choice.
This is a summary of the rules, not advice, and the final wording is for your compliance officer. Once it is agreed, Footer365 puts the right footer on every email from one place, and the free trial lets you prove it on one team first.
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Two companies, two brands and often two Microsoft 365 tenants. How to handle email signatures after a merger, from day one to the tenant move.
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