Client assets: RMAR

Ensure you do not record client trust money as an asset of your firm

In order to meet our regulatory requirements you cannot include balances held in client trust accounts, and corresponding debtors and creditors, as an asset of your firm within section A of your Retail Mediation Activities Return (RMAR). This is because funds held in trust accounts (statutory and non-statutory) do not legally belong to the firm.

Any corresponding ledger entries, for example insurance debtors and insurance creditors, should also be excluded.

You may need to review your financial position if you include client trust accounts and corresponding debtors and creditors within section A of your RMAR.

If you currently include funds held in trust accounts in Section A

You should check that you still meet our capital resources requirements.

Review your financial position after taking client trust money out to see if your firm still meets its capital resources requirement.

If you think it will not meet the regulatory requirements you should discuss the problem with your accountants, or take other professional advice on the options open to you.

You should also immediately inform us and provide an action plan for remedying the situation.

Our prudential sourcebook[1] sets out what types of capital can be used to meet your firm's capital resources requirement.

Most firms will not experience difficulties in meeting their capital resources requirement when any funds held in trust accounts are removed from their section A of the RMAR.

Including trust account balances where some or all of the funds might be due to the firm as commission that has been earned but not taken

We accept that at the end of any accounting period there will inevitably be commissions earned but not taken still in the trust account, but these should be accounted for as a trade debtor in section A of the RMAR.