RegSol Blog

CP133 - Consultation Paper on Enhancements to the Central Bank Client Asset Requirements as Contained in the Central Bank Investment Firms Regulations

December 2020

On the 3rd December 2020, the CBI opened a consultation and invited electronic submissions by email to by 10 March 2021.

The key elements of the proposals include:

  • Extending the scope and application of the CAR to include credit institutions undertaking MiFID investment business;
  • Introducing new requirements regarding client disclosure and consent, including enhancements applicable to investment firms that have obtained client consent to the use of client financial instruments and investment firms providing prime brokerage services;
  • Introducing new CAR guidance to clarify the Central Bank’s expectations as to how client funds should be segregated;
  • Introducing new requirements, and placing some existing CAR guidance on a legislative footing, in relation to the performance of reconciliations and the treatment of client asset discrepancies and reconciliation differences, and shortfalls and excesses; and
  • Introducing new requirements and CAR guidance on the contents of the Client Asset Management Plan (the CAMP).

The proposed amended rues are fully set out and a 12 month implementation period is envisaged post-publication of any new rules.

The full Consultation Paper is available HERE.

By Judy de Castro