The FCA is consulting on major changes to the client assets and client money regime, as expected since the collapse of Lehman. The proposals aim to ensure that client money is returned promptly after a firm s failure via a two-stage distribution approach and will allow multiple pooling for limited EMIR-related purposes. The FCA also proposes a number of business-as-usual enhancements. The consultation will be of interest to firms and their clients, and to banks and others holding client money.