Custody and client asset licensing requirements

Who this is for

• - Custodians
• - Managers with custody risk
• - Platforms handling client money
• - Brokers and fund operators

Trigger questions

• - Can the firm move, instruct, deduct from, or otherwise control client assets?
• - Are client assets held directly, by a custodian, by a fund vehicle, or through a platform?
• - What audit, segregation, disclosure, capital, and reporting controls are needed?

Common mistakes

• - Saying the firm does not hold assets while retaining practical control over movements.
• - Not documenting qualified custodian, CASS, client money, or safeguarding assumptions.

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