FSA has banned two directors of an insurance broker from carrying out significant influence functions for three years. It found the directors’ behaviour meant their firm breached many aspects of its client money rules, including:

  • it did not keep proper records in respect of client money; 
  • it did not make sure it kept records of client money calculations, and did not tell FSA it had failed to do so; 
  • it did not ensure the firm dealt properly with any shortfall or surplus in client money; and 
  • the firm did not give written notice to its bank that moneys in its client bank account were held by the firm as trustee.

Margaret Cole said FSA would not wait for client money to be lost before taking action against inadequate systems and controls.