The FSA has issued a Consultation Paper (CP) and Discussion Paper (DP) that proposes a number of changes to the client money and custody assets regime for firms that undertake investment business.

In addition to some changes required by the European Markets Infrastructure Regulation (EMIR), the FSA proposes changes that could lead to a radical shift in how firms protect client money.

The FSA is also seeking comment on some wider issues in relation to its fundamental review of the client assets regime with the aim of producing better results in the insolvency of an investment firm. The proposals fall under three different headings: (i) Changes required by EMIR; (ii) Introduction of Multiple Client Money Pools, (iii) Client Assets Regime: Achieving Better Results.