In terms of your funds being guaranteed by the FSCS, this sentence is not applicable, and you should not be concerned. It refers to a hypothetical situation where we decide to move client funds from an approved bank in the UK to a bank which does not qualify as “approved” which we don’t plan to do in the near future or for that matter at all. This sentence derives from the CASS rules relating to safekeeping of client assets and concerns holding of client money with a bank which is not an approved bank. This is only possible where all of the below conditions are met:
(1) the client money relates to one or more insurance transactions which are subject to the law or market practice of a jurisdiction outside the United Kingdom;
(2) because of the applicable law or market practice of that overseas jurisdiction, it is not possible to hold the client money in a client bank account with an approved bank;
(3) the firm keeps the money with such a bank for no longer than is necessary to effect the transactions;
(4) the firm notifies each relevant client and has, in relation to a consumer, a client agreement, or terms of business which adequately explain that:
(A) client money will not be held with an approved bank;
(B) in such circumstances, the legal and regulatory regime applying to the bank with which the client money is held will be different from that of the United Kingdom and, in the event of a failure of the bank, the client money may be treated differently from the treatment which would apply if the client money were held by an approved bank in the United Kingdom;
and C) if it is the case, the particular bank has not accepted that it has no right of set-off or counterclaim against money held in a client bank account, in respect of any sum owed on any other account
and (5) the client money is held in a designated bank account.
As outlined above, this is a hypothetical scenario, and we have no plans whatsoever of moving client money outside of the UK but even if we did, it will still be covered by the compensation scheme.