Client onboarding document (DER)
A mandatory document provided by the IOBSP broker to the client at first contact, containing information about the broker's status (ORIAS number, IOBSP category), usual bank partners, remuneration policy (bank commission and/or client fees), and contact details of regulatory authorities. It fulfils the pre-contractual disclosure duty and must be retained in the file.
Key points
- Must be provided before any information gathering or mandate signing.
- Contains the ORIAS number, IOBSP category, and contact details of regulatory authorities.
- States whether the broker receives bank commissions and/or charges client fees.
- Retention in the file is mandatory and may be checked by the ACPR.
Frequently asked questions
When exactly must the DER be handed to the client?
The DER must be provided at first contact, whether in person, by phone, or electronically. In practice, in a digital journey, it is embedded in the contact form or at the start of the data-collection flow, with a confirmation checkbox. No client information should be collected before this step.
Why does the DER mention the competent regulatory authorities?
This mention allows the client to know where to turn in the event of a dispute or complaint against the broker. It builds trust in the relationship and demonstrates that the broker operates within a regulatory framework. The ACPR and ORIAS are typically cited, along with the competent ombudsman for unresolved complaints.
What is the difference between the DER and the standardised information sheet (FIS)?
The DER is provided at onboarding and concerns the broker itself (who they are, how they are remunerated). The FIS, by contrast, is produced later and concerns a specific credit or insurance product offered to the client (features, cost, risks). Both documents are complementary but distinct in purpose and timing.
In practice
During a first phone appointment, the broker immediately sends a secure link to their DER; the client views it, confirms receipt with a click, and this timestamp is archived in the file before any document collection begins.
Official sources
- Article R519-22 CMF (information at entry into relationship) · Légifrance
- Article L519-1 of the Monetary and Financial Code · Légifrance
- Prudential supervision and resolution authority · ACPR (Banque de France)