On 20 October 2010, the FSA published a policy statement on enhancing its client assets sourcebook (CASS) (PS10/16) which includes confirmation of the following changes to the client assets regime:
- Increased rehypothecation disclosure and transparency requirements for prime brokers
- Restricted placement of client money deposits within a group
- Prohibition of the use of general liens in custodian agreements
- Creation of a new CASS operational oversight function
- Introduction of a client money and assets return
PS10/16 also contains details of the review the FSA conducted on the effectiveness of special purpose vehicles (SPVs) established to enable client assets to be released promptly on a firm’s insolvency.
The new rules will come into force throughout the course of 2011.