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Update on Client Money

On 25 January 2013, the FSA published Policy Development Update Number 155 detailing forthcoming publications from the FSA on a wide range of issues.  Among the client money related updates to be expected during the course of 2013 are:

  • Policy Statement relating to Part 2 of CP12/22, introducing the concept of multiple client money pools within the CASS regime.  The estimated date of publication for this Policy Statement is yet to be confirmed.  It represents a follow-up to PS 12/23: “Client assets regime: changes following EMIR”, published in December 2012, which dealt with the issues raised in Part 1 of CP 12/22 regarding porting and the status of Title Transfer Collateral Arrangements under EMIR.
  • Policy Statement to CP 12/20, “Review of the client money rules for insurance intermediaries”.  This will take the form of a review of the client money rules for insurance intermediaries and is expected to be published in Q3/Q4 2013
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