Veracent Intelligence

All questions · CAP-02 · Core criterion

Who holds client money, and under which regime is it held?

Answered for 11 of 12 firms. A binding document stating how customer money is held and by whom. Where the arrangement differs by product or by stage — held as banker before settlement and as client money after, or under scheme rules in one account and client money rules in another — record each, since a reader's protection depends on which applies to them.

Client Money: any of your Cash which is held in your Relevant F&SS Accounts, all of which is subject to the protections afforded by the FCA’s client money rules and guidance

The terms define Client Money as cash held in the customer's Relevant F&SS Accounts, all of which is subject to the protections afforded by the FCA's client money rules and guidance.

Binding document · AJ Bell Management Limited · Definitions · Check the source

Any of your SIPP or Retirement Investment Account Cash which is held pending investment from time to time, including the income from investments and proceeds from the sale of investments, may be held by Sippdeal Trustees Limited until the Cash is required for investment purposes, at which point it will be transferred to your F&SS Accounts or F&SS XO Account and held as Client Money.

SIPP or Retirement Investment Account Cash held pending investment may be held by Sippdeal Trustees Limited until required, at which point it is transferred to the F&SS Accounts or F&SS XO Account and held as Client Money.

Binding document · AJ Bell Management Limited · clause 6.2 · Check the source

Sippdeal Trustees Limited will hold Contributions paid and cash Transfers made into your SIPP or Retirement Investment Account in a Pooled Bank Account with a Bank separate from cash belonging to it until We allocate them to your SIPP or Retirement Investment Account.

Sippdeal Trustees Limited holds Contributions and cash Transfers made into a SIPP or Retirement Investment Account in a Pooled Bank Account with a Bank separate from cash belonging to it, until allocation to the SIPP or Retirement Investment Account.

Binding document · AJ Bell Management Limited · clause 6.1 · Check the source

the difference between the interest paid to us or our Group companies by a Bank on the aggregate amount of the Cash held by us with the Bank and the interest we pay to you

The terms state that customer Cash is held by AJ Bell with a Bank.

Binding document · AJ Bell Management Limited · clause 7.21 · Check the source

we will hold Cash which is not held by an Investment Manager selected by you, in your Account or F&SS Accounts or F&SS XO Account in a Pooled Bank Account or Pooled Bank Accounts with a Bank or Banks separate from cash belonging to us.

AJ Bell holds Cash which is not held by an Investment Manager selected by the customer, in the Account or F&SS Accounts or F&SS XO Account, in a Pooled Bank Account or Pooled Bank Accounts with a Bank or Banks separate from cash belonging to it.

Binding document · AJ Bell Management Limited · clause 6.2 · Check the source

SIPP investments (other than commercial property) not held by a nominee will be held solely in our name.

SIPP investments (other than commercial property) not held by a nominee will be held solely in AJ Bell's name.

Binding document · AJ Bell Management Limited · Clause 9.7 · Check the source

Any of your Cash which is held by Sippdeal Trustees Limited, whether under this clause 6.1 or clause 6.2, will be protected by being held on trust in accordance with the Scheme Rules, and not as Client Money.

Any Cash held by Sippdeal Trustees Limited under clause 6.1 or clause 6.2 is protected by being held on trust in accordance with the Scheme Rules, and not as Client Money.

Binding document · AJ Bell Management Limited · clause 6.1 · Check the source

Execution-Only Option – your SIPP funds are held by us or an Execution-Only Partner

Under the Execution-Only Option, SIPP funds are held by AJ Bell or an Execution-Only Partner.

Binding document · AJ Bell Management Limited · Clause 9.1(e) · Check the source

Pooled Bank Account: a general account in our name in which the cash of one or more customers is held but which is designated in the Bank's records as being held in trust for those customers so that the Bank may not exercise a right of lien or set-off against any indebtedness that we may have to the Bank

The terms define a Pooled Bank Account as a general account in AJ Bell's name in which the cash of one or more customers is held but which is designated in the Bank's records as being held in trust for those customers so that the Bank may not exercise a right of lien or set-off against any indebtedness that AJ Bell may have to the Bank.

Binding document · AJ Bell Management Limited · Definitions - Pooled Bank Account · Check the source

Investment Partner Option – your SIPP funds are held by your selected Investment Partner and your Adviser places orders with them directly;

Under the Investment Partner Option, SIPP funds are held by the selected Investment Partner.

Binding document · AJ Bell Management Limited · Clause 9.1(b) · Check the source

Discretionary Investment Partner Option – your SIPP funds are held by the Discretionary Investment Partner you select

Under the Discretionary Investment Partner Option, SIPP funds are held by the Discretionary Investment Partner selected by the customer.

Binding document · AJ Bell Management Limited · Clause 9.1(c) · Check the source

We hold the money and investments in CASS products in accordance with the Financial Conduct Authority's Client Assets Sourcebook safeguarding rules. This means we manage this money and these investments, but we hold the money in segregated Client Money Bank Accounts and the investments in custody accounts.

For CASS products (ISAs and the General Investment Account), the client agreement states client money is held in segregated Client Money Bank Accounts and investments in custody accounts, under the FCA's Client Assets Sourcebook safeguarding rules.

Binding document · Digital Moneybox Limited · Section 2.2.2, CASS products · Check the source

For these Savings Treasury Products, we open Trust Bank Accounts with third party banks in our name and by accepting these terms and conditions you appoint us to act as your bare trustee. We are the legal owner of the Trust Bank Accounts, and act as bare trustee on your behalf as the beneficial owner alongside our other customers invested in the same Savings Treasury Product. It is important to note that we are not a bank and your money is held in Trust Bank Accounts so we aren't ultimately responsible for keeping it safe. Selecting third party banks to hold your deposits in a Savings Treasury Product on trust is not a regulated investment service so the Savings Treasury Product is not regulated by the FCA.

For Savings Treasury Products, the client agreement states money is held on a bare trust basis across a panel of third party banks, and that this arrangement is not a regulated investment service — so the Savings Treasury Product itself is not regulated by the FCA.

Binding document · Digital Moneybox Limited · Section 2.2.2, Trust products — Savings Treasury Products · Check the source

Selecting a third party bank to hold your deposits in a Savings Product on trust is not a regulated investment service so the Savings Products are not regulated by the FCA. Deposit-taking is a regulated activity. The third party banks that we use are authorised and regulated by the Prudential Regulation Authority ("PRA") and regulated by the FCA as deposit-takers.

For Savings Products, the client agreement states money is held on a bare trust basis with the specific third party bank providing that product, and that arrangement is not a regulated investment service — so the Savings Products themselves are not regulated by the FCA.

Binding document · Digital Moneybox Limited · Section 2.2.2, Trust products — Savings Products · Check the source

We'll treat any cash that is held in your Freetrade Account(s) as 'client money', in accordance with Applicable Requirements. This means that we'll ensure your cash is held separately from our own cash.

The client agreement states that client cash is treated as client money and held separately from the firm's own cash.

Binding document · Freetrade Limited · Check the source

We'll arrange for your client money to be held in one or more bank accounts or qualifying money market funds, each with a third party financial institution that we select in accordance with Applicable Requirements.

The client agreement states that client money is held in bank accounts or qualifying money market funds with a third party financial institution.

Binding document · Freetrade Limited · Check the source

Cash in your PMS SIPP is held by HLPT on trust in SIPP Trustee Bank Accounts in accordance with the Scheme Rules and not the FCA's client money rules. It is segregated from HLPT's own funds and those of HLAM.

The document states that cash in the PMS SIPP is held by HLPT on trust in SIPP Trustee Bank Accounts and is segregated from HLPT's own funds and those of HLAM.

Binding document · Hargreaves Lansdown Asset Management Limited · Check the source

“SIPP Trustee Bank Account” means an account at a bank or credit institution in which HLPT, acting as the HL SIPP trustee, holds money belonging to you and other clients that is held within the HL SIPP;

The terms define a SIPP Trustee Bank Account as an account at a bank or credit institution in which HLPT, acting as HL SIPP trustee, holds money belonging to the client and other clients within the HL SIPP.

Binding document · Hargreaves Lansdown Asset Management Limited · Check the source

Cash we hold for you in Accounts other than the PMS SIPP is held by HLAM on trust in Client Bank Accounts and is segregated from its own funds in accordance with the FCA's client money rules and guidance.

The document states that cash held for Accounts other than the PMS SIPP is held by HLAM on trust in Client Bank Accounts and segregated from its own funds in accordance with the FCA's client money rules.

Binding document · Hargreaves Lansdown Asset Management Limited · Check the source

All cash and assets in PMS SIPP Accounts are held on trust by HLPT in accordance with the Scheme Rules.

The client agreement states that all cash and assets in PMS SIPP Accounts are held on trust by HLPT in accordance with the Scheme Rules.

Binding document · Hargreaves Lansdown Asset Management Limited · Check the source

Cash balances held in the Client Bank Accounts and SIPP Trustee Bank Accounts are expected to earn interest of between 0.5% below and 0.5% above the prevailing Bank of England base rate over the next 12 months.

The agreement states that cash balances are held in Client Bank Accounts and SIPP Trustee Bank Accounts.

Binding document · Hargreaves Lansdown Asset Management Limited · Check the source

“Client Bank Account” means an account at a bank or credit institution, in which we hold money belonging to you and other clients of Hargreaves Lansdown;

The terms define a Client Bank Account as an account at a bank or credit institution in which HLAM holds money belonging to the client and other clients of Hargreaves Lansdown.

Binding document · Hargreaves Lansdown Asset Management Limited · Check the source

your money shall be held in pooled client bank accounts at selected third party banking institutions as determined by us in accordance with the Client Money Rules

The agreement states that client money is held in pooled client bank accounts at selected third party banking institutions in accordance with the Client Money Rules.

Binding document · IG Markets Limited · Check the source

We may hold client money in a qualifying money market fund and notify you that such money will not be held as client money in accordance with the Client Money Rules and the units or shares in any qualifying money market fund will be held as safe custody assets in accordance with the provisions of the FCA Rules

The agreement states that client money may be held in a qualifying money market fund, and that such money will not be held as client money under the Client Money Rules but as safe custody assets under FCA Rules.

Binding document · IG Markets Limited · Check the source

We will treat money received from you or held by us on your behalf in accordance with the Client Money Rules.

IG Markets Limited states that money received from or held on behalf of the client will be treated in accordance with the Client Money Rules.

Binding document · IG Markets Limited · Check the source

We may hold client money in a client bank account with a bank located outside the European Economic Area.

The agreement states that client money may be held in a client bank account with a bank located outside the European Economic Area.

Binding document · IG Markets Limited · Check the source

We place Cash in one or more accounts at banks or other appropriate financial institutions.

The terms state that client cash is placed in one or more accounts at banks or other appropriate financial institutions.

Binding document · Integrated Financial Arrangements Ltd · Interest on Cash · Check the source

we may (in line with FCA regulations) remove that Cash from our client money bank account if there has been no activity on your Portfolio for six years. At that point we will write to your last-known address to ask for Instructions for paying your Cash to you. If we do not receive Instructions from you within 30 days of the date of our letter, we may remove your Cash from our client money bank account and you will lose the associated protection of having your money segregated in such an account.

The terms and conditions state that where a customer is only holding Cash in their Portfolio, the entity may remove that Cash from its client money bank account if there has been no activity on the Portfolio for six years, and the customer will lose the associated protection of having their money segregated in such an account.

Binding document · Integrated Financial Arrangements Ltd · Clause 13.3(3), Closure generally · Check the source

Where this occurs, for the duration of such shortfalls we transfer our own money (to the value of the Investments affected, recalculated daily) into a client money bank account which is subject to the FCA’s client money rules so that clients are not disadvantaged.

The terms state that where asset shortfalls occur, the entity transfers its own money into a client money bank account which is subject to the FCA's client money rules so that clients are not disadvantaged.

Binding document · Integrated Financial Arrangements Ltd · Asset shortfalls clause 4.4(4) · Check the source

We receive your Cash, as your trustee, into client money bank accounts in line with the FCA’s client money rules. This means that we hold your Cash separately from our own money.

The terms state that Cash is received as trustee into client money bank accounts in line with the FCA's client money rules, and held separately from the firm's own money.

Binding document · Integrated Financial Arrangements Ltd · 5.2 Protecting Cash · Check the source

Your money will be placed in a client money bank account with an approved bank in accordance with the client money rules.

The client agreement states that customer money is placed in a client money bank account with an approved bank, in accordance with the client money rules.

Binding document · J.P. Morgan Personal Investing Limited · Section 9.2, Client Money · Check the source

Where we hold money for you in connection with the Investment Services, we hold it in your Monzo current account only. This means we hold that money as banker

The agreement states that where Monzo holds money for the customer in connection with Investment Services, it is held in the customer's Monzo current account and Monzo holds that money as banker.

Binding document · Monzo Bank Limited · client money clause · Check the source

Once money reaches your investment account, the Investment Services Partner holds it as client money and the FCA rules on client money distribution and transfer rules will apply.

The agreement states that once money reaches the investment account, the Investment Services Partner holds it as client money and the FCA rules on client money distribution and transfer apply.

Binding document · Monzo Bank Limited · Check the source

REVOLUT LTD

Verified
invest it in low-risk assets that have been approved by our regulator, which are also kept in dedicated client accounts with financial institutions

The terms state that money may instead be invested in low-risk assets approved by the regulator, which are kept in dedicated client accounts with financial institutions.

Binding document · Revolut Ltd · How is my money protected? · Check the source

Any money, regardless of its currency, held on your behalf by us that qualifies as client money for the purposes of the FCA Client Money Rules will be protected in accordance with those rules and held in a segregated bank account, Term Deposit or held with a Qualifying Money Market Fund (QMMF) alongside the money of our other clients.

The client agreement states that client money is protected under FCA Client Money Rules and held in a segregated bank account, Term Deposit or Qualifying Money Market Fund.

Binding document · Trading 212 UK Limited · Check the source

Your money is deposited in Great British Pounds (GBP) into dedicated and segregated accounts held by us with our safeguarding institutions.

Wise's agreement states that customer money is deposited into dedicated and segregated accounts held by Wise with its safeguarding institutions.

Binding document · Wise Payments Limited · Check the source

STARLING BANK LIMITED

Does not apply

The FCA Register records this firm's client money permission as 'Control but not hold client money', and the client agreement states that its main business is taking deposits from customers. Customer money is held as a bank deposit protected by the FSCS, not as client money under the FCA client money rules, so the question of segregation cannot arise

Every firm here was asked the same question against the same published standard, and every answer quotes the passage it came from. Where the answers differ, the difference is in the firms’ own documents, not in how we read them.

Darker text marks stronger evidence. A statutory register prints at full strength; a firm’s own marketing prints lighter. The methodology sets out the weightings.