FCA’s Final Rules On Client Assets Regime

On 10 June 2014, the FCA published its Policy Statement, including feedback and final rules, following the review of the client assets regime for investment business. Investment firms and other financial institutions that conduct investment business and hold client money, custody assets, collateral or mandates in relation to investment business, including loan-based crowdfunding firms, will need to review the new rules and change their systems and procedures to ensure compliance with the revised rules. The rules, which will become fully enforceable on 1 June 2015, are being phased in. Firms that are a clearing member of a CCP will be permitted, subject to certain requirements being met, to offer multiple client money sub-pools for net margined omnibus client accounts at CCPs. The FCA is not extending the rules to other areas because of the complexities of operating sub-pool accounts and it appears that only other business models in terms of client money held by CCPs