Payment or e-money firm? Due diligence on the banks that hold your safeguarded funds, under CASS 15. See safeguarding files
For advisers reviewing a platform
Platform due diligence often leans on the platform’s own literature and a questionnaire it completed itself. The record that matters most is published by the regulator and Companies House, and it is easy to miss.
From the FCA Register · Transact
“IFA did not perform any internal reconciliation (client money calculations) between 2001 and 2010 and as a consequence failed to identify or fund any shortfalls in its client money bank accounts.”
It is fifteen years old, and the register records the firm as authorised since 2001. The point is not that the platform is unsafe. It is that this is published by the regulator itself, and a due-diligence file that does not mention it is incomplete.
The brand is not the firm
Permissions, client money and liability sit with a legal entity whose name your clients have never seen. Every report starts by tracing the brand to it.
A review is a snapshot
An annual review reads the register once a year. The entry can change in any week: a new requirement, a restriction, a disciplinary entry, a lost permission.
Someone will ask how you know
Compliance, an auditor, the regulator. A finding without a source is an opinion. Every line we publish quotes the passage it rests on.
The platform due-diligence file · £149 a year
The platform’s full evidence record, addressed to your firm and verifiable by anyone you show it to. An adviser summary, the register record as read on the day, the questions public sources did not answer, and a sign-off page for your review. Then a year of weekly register checks, with an email the week anything changes.
Who holds client money, and under which regime is it held?
the difference between the interest paid to us or our Group companies by a Bank on the aggregate amount of the Cash held by us with the Bank and the interest we pay to you
The terms state that customer Cash is held by AJ Bell with a Bank.
Which entity acts as custodian of client assets, and is it a separate legal entity from the operator?
We also accept full responsibility for any obligations it may owe you if it becomes insolvent.
The terms state that the firm accepts full responsibility for any obligations Transact Nominees Limited may owe the client if it becomes insolvent.
Are there requirements, restrictions or waivers on the permissions?
the Firm must not, without the prior written consent of the FCA, onboard any new customers to its business savings account
The register records that the firm must not onboard new business savings customers without the FCA's prior written consent.
Are there published warnings or unauthorised-firm alerts naming this entity or a clone?
This is the genuine, authorised firm that the fraudsters are claiming to work for. It has no connection with the clone firm. The correct details are: Firm Name: J.P. MORGAN PERSONAL INVESTING LIMITED Firm Reference Number: 552016
The FCA published a separate warning, first published 27/05/2022, about a clone firm using the name 'Nut-Meg'; the warning's 'FCA authorised firm details' section names J.P. Morgan Personal Investing Limited, firm reference number 552016, as the genuine authorised firm the fraudsters were claiming to work for.
We do not publish a score. Any single figure would mean weighting one thing against another — a judgement that cannot be evidenced, and one that would turn a factual statement about research into an opinion about a company. Each report states how much of the evidence we could find, and shows you all of it.
The same question asked of every firm at once is on the comparison pages — which compensation scheme covers them, who holds client money, what each may do with client assets. How all of it is produced is set out in the methodology, and every question we ask is listed in the criteria.