The Financial Conduct Authority (FCA) is consulting on proposals to strengthen the safeguarding rules for payment and e-money firms, to introduce CASS-like measures to increase protection for customer funds when firms become insolvent. These range from record keeping and monitoring requirements, to protections around safeguarded funds (extending to trusts), and governance duties.
The FCA's consultation closes on 17 December 2024, with the FCA expecting to publish its final interim rules and accompanying policy statement in the first half of 2025. For firms to which the proposals set out in the FCA's consultation apply it would be prudent to consider the potential impact on your business and provide responses to the FCA by 17 December.
This note sets out the background to a rationale for the consultation, as this is central to understanding the proposals the FCA makes. It summarises its implications for firms in-scope in the medium and long-term, and a summary of next steps.
and then 