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Client Money

Protecting Client Money: The Foundation of Trust

Client money protection sits at the heart of UK financial services regulation. It is more than a rulebook requirement — it is a professional duty, a reputational safeguard, and a key driver of trust between firms and their clients.

At CMAC, we help you navigate the FCA’s CASS 7 rules with clarity, practicality, and community support. Whether you are a seasoned CASS Oversight Officer or building your client money framework for the first time, this page provides actionable guidance, best practice tools, and curated resources to help you achieve robust and compliant client money controls.

What Is Client Money?

Client money is money received or held by a firm on behalf of its clients in the course of investment business. Under CASS 7, this money must be identified, protected, and segregated to ensure it is never at risk in the event of firm failure.

Why It Matters:

  • Protects clients' assets and confidence

  • Reduces regulatory and reputational risk

  • Enables orderly wind-down or insolvency protection

Core Requirements Under CASS 7

Segregation

Client money must be held in trust in designated client bank accounts.

Acknowledgement Letters

Firms must secure written confirmation from banks to recognise the trust status.

Daily Client Money Calculation

Required to determine amounts due for segregation.

Recordkeeping

Detailed, accurate records support transparency and audit readiness.

Reconciliation

Timely reconciliation ensures discrepancies are detected and resolved.

Best Practice Guidance

  • 1. Setting Up Client Bank Accounts

    • Use FCA-compliant templates for trust acknowledgement letters

    • Maintain an approved bank list with appropriate due diligence

    [Access Template Letters →] (Download link)

    2. Segregation & Prudent Assessment

    • Understand the timing of segregation

    • Apply the “prudent approach” to uncertainty in client entitlements

    [Segregation Walkthrough →] (Internal CMAC resource link)

    3. Daily Calculations (ICMC)

    • Internal Client Money Calculation (ICMC) methods explained

    • Common reconciliation pitfalls and how to avoid them

    [View ICMC Calculator Template →] (Download link)

    4. Reconciliation Tips

    • Why external and internal reconciliations differ

    • How to manage “breaks” and track remediation timelines

    🛠️ [Reconciliation Tracker →] (Internal tool or spreadsheet)