Murky depths of client money pool proposals

Many industry participants are struggling with what is already a complex regulatory regime for handling client assets; yet the FSA’s proposals on multiple client money pools could considerably augment these challenges reports Judith Cromwell.

Judith Cromwell is a consultant at Bovill, where she specialises in the regulation of retail financial services firms. She has previously spent five years working for the FSA. Reach her at jcromwell@bovill.com.

CP12/22, a combined consultation and discussion paper titled ‘Client assets regime: EMIR, multiple pools and wider review’ was published on 6 September 2012. Final rule changes to the client assets sourcebook (CASS), which will be necessary to accommodate segregation and porting requirements under the European Market Infrastructure Regulation (EMIR), will be published this month.