APCIMS has responded to parts two and three of FSA’s consultation “Client assets regime: EMIR, multiple pools and the wider review”. It finds that mandated segregation of retail from non-retail assets into different pools would be disproportionate. The proposals for multiple client money pools may be appropriate to deal with the default of major firms, but those that APCIMS represents operate less complex business models. (Source: APCIMS Response to CP12/22)