For further information: www.fsa.gov.uk/smallfirms
The Client Money Health Check is not an exhaustive checklist but is designed to help firms assess their
understanding of client money and how it should be protected. The Health Check can help firms identify
any areas of weakness in their systems and controls for protecting client money.
If you answered mostly yes to these questions, you probably have most of the basic systems in place to:
Set up a trust bank account with your firm as trustee (or in Scotland as agent); and
Protect client money from any claims on it by your bank.
If you answered no to any question, you are likely to have a more limited understanding about how to
protect your clients’ money and we recommend you read Chapter 1 of the Guide to Client Money for
General Insurance Intermediaries or alternatively take the e-learning course.
SETTING UP TRUST ACCOUNTS
Have you set up a separate bank account for client money?
Does the title of your client money account(s) distinguish it from other accounts of
your firm for example, by including the words ‘client’ or ‘client money’?
Do you have in writing from your bank confirmation that all money held is held
by your firm as trustee (or in Scotland as agent)?
Do you have the bank’s written confirmation that the bank is not entitled to
combine the client money account(s) with any other account or to exercise any
right or set-off or counterclaim against money in that account in respect of any
sum owed to it on any other account of the firm?
CLIENT MONEY TRANSACTIONS
Do you pay all money into a client trust bank account on the day you receive it
or by close of business the following day?
Do you ensure money received by automated transfer is received into a client
trust bank account?
Do you pay mixed remittances (a payment comprising money for insurance products
and money for some other service or goods) into a client trust bank account?
Do you remove money for other goods or services and money owed to your firm