On 10 June 2014, the FCA published its long-awaitedpolicy statement and accompanying guidance notedetailing changes to the client assets regime in the UK following the proposals made in Consultation Paper CP 13/5, published in July 2013.
The policy statement represents a material rewrite of the CASS regime in the UK. The most significant amendments, many of which will have an impact on firms’ documentation processes, are detailed below. However, of note is the fact that the FCA does not intend to proceed with its main proposal – regarding changes to the client money distribution rules (i.e. the rule that ‘speed’ should take priority over absolute accuracy), although it will keep these rules under review and further consult on the topic later in the year.[Footnote 1] In addition, it believes that a number of the recommendations made by Peter Bloxham regarding the operation of the Special Administration Regime (see here for more information) are likely to be addressed by the changes detailed within the policy statement.
Footnotes for this section:
 Paragraph 1.13
 Paragraph 1.15