Custody and client asset operations licence map

Who this helps

• - Custody operations staff
• - Client asset owners
• - Platform operators
• - Fund operations teams
• - Brokerage operations leads

Typical job titles

• - Custody operations manager
• - Client assets officer
• - CASS owner
• - Fund operations manager
• - Clearing and custody lead

Core question

Can the firm or person hold, move, instruct, deduct from, reconcile, safeguard, or otherwise control client money, securities, fund assets, or custody records?

Activity triggers

• - The firm receives, controls, transfers, deducts fees from, or instructs movement of client money or securities.
• - Client assets are held through a custodian, broker, fund vehicle, platform wallet, omnibus account, or clearing arrangement.
• - The role owns reconciliations, custody statements, safekeeping records, segregation, possession/control, or client asset reporting.
• - The model involves discretionary management, private funds, custody audits, CASS, clearing/carrying, or client money returns.
• - Outsourced custody, platform, administrator, or broker arrangements are relied on to avoid direct asset handling.

Licence and registration map

• - UK: check CASS position, client money and safe custody asset controls, CASS firm type, SM&CR ownership, and FCA permission impact.
• - US: check RIA custody, qualified custodian, fee deduction, private fund audit, broker-dealer clearing/carrying, and state custody questions.
• - Singapore: check CMS providing custodial services, fund management/dealing overlap, MAS FID activity, and representative/control evidence.
• - Hong Kong: check Type 1/4/9 workflow, client asset handling, financial resources, internal controls, and responsible officer/MIC ownership.
• - Australia: check AFSL custodial/depository service, dealing/advice overlap, responsible manager competence, and financial resources evidence.

Exam or competence checks

• - Custody competence is usually proved by role experience, controls, reconciliations, audits, and accountability evidence, not a single exam.
• - US broker-dealer operations staff may need Series 99 if covered operations functions apply.
• - A CASS, custody, or client-assets owner may also be part of SM&CR, responsible officer, responsible manager, or key-person evidence.

Application evidence

• - Custody and client asset trigger memo.
• - Money and asset flow diagram from onboarding to exit.
• - Custodian, broker, administrator, clearing, and platform due diligence files.
• - Reconciliation, segregation, statement, audit, incident, breach, and escalation procedures.
• - Capital, insurance, wind-down, and client-notification evidence tied to the custody model.

Register checks

• - Check firm permissions, conditions, and custody/client-asset activities in public registers.
• - Check whether third-party custodians, brokers, and administrators are authorised in their own right.
• - Record direct custody, practical control, fee deduction, and outsourced custody assumptions separately.

Jurisdiction notes

Common mistakes

• - Saying there is no custody because assets sit with a third-party custodian while the firm can still instruct movement or deduct fees.
• - Treating CASS or qualified-custodian analysis as a footnote after permissions and capital are chosen.
• - Not checking whether outsourced custodians, brokers, or administrators are authorised and operationally credible.

Disclaimer

Information on LicenseCompare is for general educational purposes only and does not constitute legal, regulatory, financial, tax, investment, or professional advice. Licensing requirements depend on facts and change over time. Always consult official regulator materials and qualified professional advisers.