JustUs Barclays Ring-Fenced Protected Client Accounts.

A number of queries have been raised on the P2P forum around FCA Regulated Client Money Accounts.

I will aim to clarify the position. When you open a segregated client account with any bank - you have to determine your firms regulatory status. It's very simple.

You are either;

(1). FCA Regulated
or
(2). Non Regulated

(1) FCA Regulated: The bank and the platform have to sign a separate written client account money agreement, in addition to the normal bank's segregated client account terms and conditions. The additional written agreement has to be written verbatim as per FCA CASS Client Money Rules. The platform should also have the Client Money permissions showing on the FCA register. I recommend all lenders check the client money status of their platform, it takes 20 seconds register.fca.org.uk/

(2) Non Regulated: The firm does not have FCA regulated client money permissions. 

Banks are under no obligation to provide FCA Regulated Client Money accounts, in-fact it's very hard to obtain them.

You may have money with a P2P platform that is FCA Regulated, but have been unable to secure FCA client money permissions or open the required client accounts. This is why firms use 3rd party payment providers. As far as I am aware, and I may stand corrected, but to offer the Innovative Finance ISA - you need to have your own firms FCA Regulated Client Money Accounts, at JustUs we have separate ones for ISA money and non-ISA money.