global insurance management

Client Money - Update

Jan 27 2014

Client Money rule changes - update

Relevance:                   All firms.

Action required:           None at this stage. Update only.

Some time ago – September 2012 to be precise – we alerted firms to the publication of an important consultation from the then regulator, the FSA.  The proposals made were an attempt to clean up and clarify many issues surrounding the arrangements for dealing with Client Money.

The consultation closed on 30 November 2012 and at the time it was expected that final rules would be published in June 2013, with implementation 12 months later.

Since then the only information that has been coming out of the FCA is that implementation has been delayed and there is currently no firm commitment to a publication date for the rules.

We have recently seen a number articles and mail alerts on this topic. None of these say anything new but they are suggesting that firms make preparations for the rule changes.

Much more importantly, the FCA is currently undertaking some thematic work on compliance with current client money rules.

So, we believe that firms should continue to apply the current rules on Client Money vigorously and ensure they are not overlooking any aspect relevant to their own business arrangements.  As and when the proposed changes are then given a proper timescale, the necessary action can then be taken.

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