FSA has issued finalised guidance and a Dear CEO letter to clarify that brokerage or portfolio management firms carry on a CREST regulated activity where they use CREST in relation to clients’ investments which are held by a nominee company in the firm’s group. Firms were trying to rely on the exclusion available when CREST is used on behalf of another member of the same group. FSA says that at least one link in the transaction chain needs to hold the relevant permission and the existence of the nominee does not mean that the firm is no longer acting on behalf of its clients. Firms have six months to review their permissions. (Source: The Use of the Group Exclusion and the CREST Regulated Activity and Sending Dematerialised Instructions in CREST)