FCA client assets regime
FCA client assets regime

The following Financial Services guidance note provides comprehensive and up to date legal information covering:

  • FCA client assets regime
  • What does the FCA’s client assets regime cover?
  • General applicability of CASS
  • Application of CASS firm classification and operational oversight requirements
  • Firm classification
  • Operational oversight
  • Reporting
  • CASS Resolution Pack
  • Enforcement action relating to client assets failings

What does the FCA’s client assets regime cover?

The client assets regime contains some of the most significant regulatory requirements found in the Financial Conduct Authority (FCA) handbook and the adherence to the provisions is crucial for all firms to whom the Client Assets Sourcebook (CASS) apply. The FCA takes breaches of CASS requirements very seriously. Also on 23 September 2014, the FCA fined Barclays Bank plc £38m for putting £16.5bn of client assets at risk. At the time, this was the highest fine ever imposed by the Financial Conduct Authority (FCA) or its predecessor the Financial Services Authority (FSA) for client assets breaches, reflecting ‘significant weaknesses’ in the systems and controls in Barclays’ Investment Banking Division between November 2007 and January 2012 and the number of affected accounts. See the FCA's press release for more information. The Barclays' fine was eclipsed on 15 April 2015 when the FCA fined The Bank of New York Mellon London Branch (BNYMLB) and The Bank of New York Mellon International Limited (BNYMIL) a total of £126m for failing to comply with the CASS custody rules. See the FCA's press release for more information. In addition, on 5 October 2016, the FCA fined Aviva Pension Trustees UK Limited and Aviva Wrap UK Limited £8.2m for client money and client assets failings. See the FCA’s press release