IMA has responded to FSA's consultation on client assets. It wonders whether it would be mandatory to have multiple client money sub-pools. It sees certain advantages with the flexibility sub-pools would provide but is also concerned about the complexity of the arrangements. IMA also believes the proposals focus too much on retail investors, and comments on the need for firms to explain the rationale and costs of setting up sub-pools which might be of benefit to only some of their investors. It agrees that assets should be returned to investors as quickly as possible following the insolvency of a firm, but wants FSA to give further thought to its proposal to dislocate the primary pooling events from a firm's failure which would allow an insolvency practitioner to sell as a going concern. Overall, IMA urges FSA to consider the proposals from a Treating Customers Fairly (TCF) perspective and to consider how it would implement the rules should they become mandatory. (Source: IMA Responds on Client Assets)