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Client Money

Client money is a critical area of compliance and a firm’s handling of it is even more visible to the FCA now that RMAR (Retail Mediation Activities Return) has been extended to incorporate wider client money reporting.

It is a complex area of regulation and one where we often uncover breaches during consultancy visits, most frequently because the firm simply wasn’t clear about what, and how, FCA requirements apply.

We can help at many levels. For example, we can look at your business processes and needs and set out the client money handling options; we can provide guidance on how to interpret your TOBAs with insurers so you are clear what arrangements apply in respect of client money/risk transfer.

We can take you through the differences between statutory trust client accounts, non-statutory trust client accounts and insurer trust (risk transfer) accounts and help to ensure such accounts are properly established and used.

We can provide training for those responsible for client money in the business or offer more hands-on support, working with you to check your procedures against FCA rules to ensure sure there are no gaps.

The client money rules can be a very challenging area for brokers and intermediaries but at Thistle we have the experience and the expertise to help you navigate the regulations compliantly and efficiently.


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