Adequate client money arrangements for general insurance intermediaries

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On 30 September, the FCA issued a Dear CEO letter for insurance intermediaries setting out their concerns over the handling of client money.

Despite being relatively concise, the letter covered a huge number of topics at quite a high level.

Behind a number of the FCA statements are some expectations which, if not met, could mean that your firm is not complying with the CASS 5 rules in the way the FCA expects. This document contains the key messages from the Dear CEO letter and our interpretation of what they mean in practice. The application of the letter will be different for each firm and our comments are intended to be a guide only.