Client Assets

Introduction When I started in securities custody there were no specific laws or rules about it, few regulators knew what it was, accounts were opened for new clients on the strength of a telex request and contracts to look at as precedents, if there were any at all, were two, perhaps as many as six […]

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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 […]

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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 […]

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On 26 April 2013, the FCA published its first Policy Development Update (PDU) for April 2013 which details forthcoming FCA publications relating to a number of areas, including RRP, client assets and EMIR, as detailed below. High level standards Initiative Current Expected Publication Date Previous Expected Publication Date Recovery and Resolution Plans: policy statement to CP11/16 […]

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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 […]

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