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On 1 August 2017, the FCA published consultation paper CP17/29 on client money and unbreakable deposits, which sets out minor amendments to CASS.

The FCA has found that some firms are experiencing some difficulty depositing client money with banks. CASS 7 prevents firms from placing client money in bank accounts with unbreakable terms of longer that 30 days. Banks however have reduced appetite for client money under such terms, due to the associated cost of liquidity requirements.

CP17/29 proposes that firms can hold a proportion of client money in unbreakable deposits of up to 90 days. CASS medium and large firms would be required to report client money in unbreakable deposits of 31-90 days in their CMAR.

By making these proposals, the FCA are seeking to prevent the potential harm to consumers if a firm reaches a point where it is unable to deposit client money at banks that meet its risk tolerance.

This could possibly result in client money being returned to clients against their wishes, or being deposited with banks that do not meet due diligence requirements.

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To arrange a confidential discussion or a tailored AutoRek CASS demonstration, please call us on +44 (0) 845 603 3613 or schedule an AutoRek Demo.