Primary pooling event

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CASS Anatomy™

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IMPORTANT: CASS changed quite a bit after MiFID II. This resource therefore may well be out of date, even if it was accurate once, which it might not have been. This is an article about the FCA’s custody and client money rules — client assets — and is fondly known by its chapter in the FCA SourcebookTable of Contents | 1 | 1A | 3 | 5 | 6 (custody rules) | 7 (client money rules) | 7A | 8 | 9 (PBDA) | 10

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In the world of the FCA’s CASS 7 client money rules, a primary pooling event happens when the entity offering client money protection fails or goes bust. In this case balances of all the accounts it has opened with client money banks should be pooled and shared out amongst its clients pro-rata according to their own claims on that client money. Of course, if there has been only a primary pooling event and n secondary pooling events, the clients should recover 100 cents on the dollar, precisely because the entity who has blown up did not have any beneficial claim on the client money.

But in rare cases (such as where the entity offering client money protection is also an approved bank which holds money on behalf of intermediaries in a clearing chain — could happen — a primary pooling event could also be a secondary pooling event.