CP17/29: Client money and unbreakable deposits

Open consultation: CP17/29
Consultation closes

We are consulting on proposed changes to the Client Assets sourcebook (CASS) on depositing client money in unbreakable deposits.

Show CP17/29 (PDF)

Some investment firms are experiencing difficulty depositing client money at banks in accordance with CASS requirements. The proposals in this paper are intended to address the potential harm to consumers resulting from this.

We are seeking feedback on the following proposed changes to CASS:

  • permit a firm to deposit an appropriate proportion of client money in an unbreakable deposit of a maximum of 90 days
  • where a firm deposits client money in an unbreakable deposit of 31 to 90 days, it must comply with certain conditions
  • require CASS medium and large firms to report client money in an unbreakable deposit of 31 to 90 days in their client money and asset return (CMAR).

Our proposals are intended to enhance our client assets regime and improve consumer outcomes by ensuring client money continues to be appropriately protected when it is held by firms.

Who this applies to

This consultation principally affects or is of interest to:

  • regulated firms that hold client money in relation to investment business
  • banks that deposit client money
  • auditors in relation to the provision of client assets audit reports

What you need to do

Please send us your comments by 1 November 2017: 

Online response form

You can also:

  • email [email protected] or
  • write to: Client Assets Policy, Client Assets and Resolution Department, Financial Conduct Authority, 25 The North Colonnade, London E14 5HS

Next steps

After considering all feedback, we aim to publish a policy statement making final rules. Our current expectation is for the rules to come into force concurrent to the Handbook changes required by the Markets in Financial Instruments Directive II (MiFID II) coming into force.

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