Focused comparison
United Kingdom custody/client assets vs United States custody/client assets
A focused comparison for custody/client assets businesses choosing between United Kingdom and United States.
| Question | United Kingdom | United States |
|---|---|---|
| Likely route | FCA safeguarding, custody, CASS, arranging custody, and prudential analysis | Investment adviser custody rule, qualified custodian, broker-dealer custody, and state custody analysis |
| Key people | Senior Manager Function approval where a controlled function applies Certification for relevant staff under SM&CR where applicable | Investment adviser representatives may require state registration depending on facts Broker-dealer registered representatives require firm sponsorship, CRD filing, exams, and registration |
| Corporate evidence | Custody and client assets; Capital and financial resources; Compliance framework; Outsourcing and vendors; Regulatory reporting; Official-source route memo; Public register verification plan; Questions log for qualified advisers | Custody and client assets; Capital and financial resources; Compliance framework; Outsourcing and vendors; Regulatory reporting; Official-source route memo; Public register verification plan; Questions log for qualified advisers |
| Capital/resources | Capital and prudential requirements depend on the permissions, MiFID/MIFIDPRU status, client asset position, and business model. | Adviser capital rules are usually state-specific or tied to custody and other facts; broker-dealers face SEC net capital and FINRA membership expectations. |
| Timeline | FCA service standards distinguish complete and incomplete applications; practical timelines often run 4 to 10+ months. | SEC adviser registration can become effective in about 45 days if complete; FINRA new member review may run up to 180 calendar days for substantially complete applications. |
| Common bottlenecks | Permissions requested do not match the actual operating model Financial forecasts are inconsistent with the applicant legal entity or prudential category | Broker-dealer issues hidden inside compensation, solicitation, placement, or transaction workflows Custody, private fund audit, and fee deduction arrangements not fully analysed |