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Client Money and Asset Segregation Rules in Retail Brokerage: How Segregation, Reconciliation and Insolvency Protections Work

How Segregation Keeps Your Brokerage Money Safer

Segregation rules, reconciliation checks and insolvency protections work together to keep client money separate from a broker's own cash — here's what that means for you.

Published · 2026-09-25

Your money, the firm's money — and why the difference matters

Imagine handing your coat to a cloakroom attendant. You expect it back — not a similar coat, not an IOU, not a promise that they'll sort it out later. Your coat. That's roughly the idea behind client money segregation in retail brokerage: when you deposit cash with a regulated firm, the rules generally require that money to be kept apart from the firm's own money, so it can be identified and returned to you if the firm runs into trouble.

It sounds simple. In practice, it involves an entire architecture of rules, records and checks — and a fair amount of paperwork. Let's walk through how the pieces fit together.

What segregation actually means

Segregation is the practice of holding client money in separate accounts, clearly identified as belonging to clients rather than to the firm. In the UK, the Financial Conduct Authority's Client Assets Sourcebook — known as CASS — sets out these requirements for firms that hold or control client money or custody assets (meaning investments like shares held on your behalf).

The rules aren't identical everywhere. In the United States, futures commission merchants — firms that handle customer trades in futures and options — must separately account for all customer funds and keep them segregated from the firm's own money. Accounts must be titled for the benefit of customers, and the firm must obtain written acknowledgements from depositories confirming that the bank or clearinghouse cannot claim a right of offset against those accounts for the firm's debts. That last detail matters: without it, a bank owed money by the firm might try to dip into the very account holding your funds.

Different jurisdictions take different approaches, and the details — what's covered, what isn't, and how quickly firms must act — vary. If you're unsure which regime applies to your account, that's a question worth asking your firm directly.

Reconciliation: the regular stocktake

Segregation only works if the firm actually knows how much it should be holding for each client, and how much it actually holds. That's where reconciliation comes in — a periodic check that the two numbers match.

Under CASS, firms should be able to account to all clients for sums held for them at all times, with money allocated to the relevant client promptly — no later than ten business days after receipt. In the futures world, a firm must at all times maintain in segregation an amount at least equal to the total it owes its customers, calculated through a specific formula covering credit balances, debit balances and permitted adjustments.

The logic is pleasantly human: count what you've got, count what you owe, and investigate the gap. When a firm can't explain a gap, that's a red flag.

Some firms go further by holding extra of their own money in the client account as a buffer against anticipated risks — an approach often called prudent segregation. It's designed to reduce the chance of a shortfall if something goes wrong, though specialists note it should be targeted at specific, identified risks rather than used to paper over operational weaknesses.

What happens if the firm fails

This is the part most people actually care about. If your broker becomes insolvent, what protects you?

In the UK, the CASS rules include specific provisions for what happens when a firm enters liquidation. Where all the client money rules have been followed, the intention is that client money can be identified and returned. The rules also address a second scenario — what happens if the bank holding the client account fails, known as a secondary pooling event — and set out how any loss is shared among affected clients.

In the United States, customer funds held in segregation under futures rules have a bankruptcy preference in the event of a firm's insolvency. That doesn't mean customers are made whole automatically: to the extent that customer funds aren't sufficient to pay customer claims, the remainder participates pro rata in distributions to the firm's unsecured creditors, alongside other creditors.

For securities accounts, the US has a separate framework: the Securities Investor Protection Act, or SIPA, which established the Securities Investor Protection Corporation (SIPC). When a brokerage fails, SIPC typically arranges for accounts to be transferred to another firm. If that isn't possible, the firm is liquidated, and SIPC advances funds to satisfy customer claims — up to $500,000 per customer, including up to $250,000 for cash.

What these protections do not cover

Here's the bit that often gets lost. SIPC protection covers the custody function — it works to restore the securities and cash that should be in your account when a liquidation begins. It does not protect against a decline in the market value of your investments. It doesn't cover losses from bad investment advice or an unsuitable recommendation. And it doesn't rescue you if you were sold a worthless stock.

Coverage also depends on what you hold. Commodity futures contracts are generally not protected by SIPC unless held in a special portfolio margining account, and crypto assets are treated differently depending on whether they qualify as securities under the relevant law — many do not. If you hold digital assets at a brokerage, the answer to "am I covered?" may well be no, even at a SIPC-member firm.

There's also a useful distinction for UK readers: money held in a bank deposit is typically covered by deposit insurance up to a set limit, whereas client money held under investment rules is protected differently. They're different schemes for different situations.

Title transfer arrangements: when ownership moves

One area worth understanding is something called a title transfer collateral arrangement, or TTCA. In simple terms, you agree to transfer full ownership of your money to the firm as collateral — for example, to cover possible obligations to the firm. Once ownership transfers, the money is generally no longer treated as client money. That's a meaningful difference from money held in a client bank account, where ownership stays with you.

UK rules tightened around these arrangements, requiring firms to consider and document whether their use is appropriate, to highlight the risks and effects to clients, and to terminate certain arrangements for retail clients entered into before January 2018. If your firm asks you to sign a TTCA, it's worth understanding precisely what you're giving up. The rules require firms to explain the risks — take them up on it.

Money can leave client status in other ways too

Client money isn't a permanent label. Money becomes the firm's own — no longer client money — when it becomes properly due and payable to the firm, for example when a firm acts as principal in a contract or has already paid for securities on your behalf. Unclaimed balances can also be released in narrow circumstances: under CASS, if a firm can't trace a client after six years of inactivity, it may be able to pay a balance to charity, provided it has made genuine attempts to find the client and provides an undertaking to pay the sum if the client later comes forward.

The practical takeaway

Segregation, reconciliation and insolvency protection form a chain. Segregation keeps your money identifiable; reconciliation makes sure the numbers add up; and protection schemes such as SIPC or the CASS distribution rules step in if a firm fails.

But no framework is identical across countries, and none of them protects you from market losses or poor advice. The useful question isn't "is my money completely safe?" — it's "which protections apply to what I hold, and what falls outside them?" That's a question worth asking your firm, and worth asking before you need the answer.

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Research sources reviewed

  1. CASS 7 Client money rules - FCA Handbook (handbook.fca.org.uk)
  2. Futures Commission Merchants (FCMs) | CFTC (cftc.gov)
  3. FR05/11 Survey of Regimes for the Protection, Distribution ... (iosco.org)
  4. AC Publications (iosco.org)
  5. Securities Investor Protection Act (SIPA) (uscourts.gov)
  6. 17 CFR § 1.20 - Futures customer funds to be segregated ... - LII (law.cornell.edu)
  7. Prudent Segregation Under CASS: Key Considerations (ocorian.com)
  8. The CASS Rules and how they may apply to you (menzies.co.uk)
  9. What Is CASS? Rules & Regulations Explained (aurum.solutions)
  10. Understanding CASS Regulation: Safety and Segregation ... (finance.yahoo.com)
  11. For Investors - What SIPC Protects (sipc.org)
  12. SIPC (sipc.org)

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