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But for the grace of God? BoNY Receives Record Fine for CASS Breaches

Introduction On 14 April 2015, the FCA published its final notice fining The Bank of New York Mellon London Branch and the Bank of New York Mellon International Limited (together, “BoNY”) a total of £180 million (reduced to £126 million on account of early settlement) for failure to arrange adequate protection of safe custody assets […]

CASS RP Bites on Small Alternative Investment Fund Managers

Life for “small AIFMs” [1] will change in a big way on 1 April 2015 and, despite the date, it’s no joke… In Policy Statement 13/5, the FCA made certain amendments to its client assets (CASS) rules in order to ensure that they remained consistent with the Alternative Investment Fund Management Directive (AIFMD) and to […]

Zut Alors! CASS RP to go all European?

Introduction The requirement to create and maintain a CASS Resolution Pack (CASS RP), formed a key plank in the FCA’s review of the client assets regime in the UK.  It requires each firm which is subject to CASS Chapter 6 (Custody rules) or Chapter 7 (Client money rules) to collate certain information regarding its handling […]

FCA CASS Review Leads to CASS RP Amendments

On 10 June 2014, following its original July 2013 consultation paper[1] the FCA published its long-awaited policy statement  and accompanying guidance note detailing changes to the client assets regime in the UK. The policy statement represents a material rewrite of the CASS regime in the UK.  The most significant amendments are summarised here.  A number […]

CASS RP Changes on the Horizon?

On 14 January 2014, HM Treasury published the “Final review of the Investment Bank Special Administration Regulations 2011” conducted by Peter Bloxham.  The report meets Parliament’s requirement that the Treasury hold an independent review of the special administration regime (SAR) for investment banks within two years of it coming into force. Five firms have gone […]

Towergate Insurance Misallocates £15m of Client Money

Firms continue to take inadequate steps to ensure compliance with the Client Money rules.  The latest case involving insurance broker Towergate highlights the FCA’s renewed sense of purpose and the fact that insurance brokers are not immune. The broker misallocated £15m of client and insurer money over a four year period (from November 2007 to […]

FCA Fines Aberdeen £7.2m for Client Money Breaches

On 3 September 2013, the Financial Conduct Authority (FCA) published a press release announcing the final notice it has issued to Aberdeen Asset Managers Limited and Aberdeen Fund Management Limited (“Aberdeen”), fining the firm £7,192,500 for breaches of the FCA’s client money rules.  This fine included a 30% discount for early settlement by Aberdeen. Over […]

FCA Update on RRP and CASS

On 26 April 2013, the FCA published Policy Development Update No 157.  This summarises the anticipated publications dates for various pieces of regulatory guidance.  Of note are the following: a policy statement (PS12/5) to CP11/16 on recovery and resolution plans, due for publication in Q2 2013; a policy statement to part 2 of CP12/22 on […]

CASS RP Webinar Tomorrow

Just a reminder that I am giving a webinar on CASS Resolution Packs for Insurance Intermediaries tomorrow at 3:30 pm.  The event is free and you can register here.

FSA Update on RRP and CASS RP

On 25 February 2013, the FSA published Policy Development Update Number 156 detailing forthcoming publications from the FSA on a wide range of issues, including: RRP: Policy Statement to CP11/16 and PS12/5 on recovery and resolution planning.  This is expected to be published in Q2 2013; and CASS RP: Policy Statement to CP 12/20, “Review […]

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