MiFID Documents

Revolut Trading Ltd - Client Assets Protection Summary

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1. Introduction

Revolut Trading Ltd (“Revolut Trading”, “we”, “our”, “us”) is authorised and regulated by the Financial Conduct Authority (“FCA”) (FRN 933846). In the course of providing investment and custody services to you, we may receive, hold and control money and financial instruments on your behalf. Money that we hold for you in accordance with the FCA client money rules is referred to as “client money”, and financial instruments that we safeguard for you are referred to as “custody assets”. Together, we refer to these as “client assets”. This summary provides you with important information on, and explains at a high level, how we protect your client assets in accordance with the FCA’s Client Assets Sourcebook (“CASS”) rules and other applicable regulatory requirements, the principal risks that may arise and what may happen in certain circumstances, including if we or a third party that holds your client assets fails.


This summary does not cover every risk associated with our services. It is important that you read this summary together with the following documents, which, collectively, form your agreement with us:


Terms not defined in this summary shall have the meaning given to them in the Terms of Business Omnibus.

2. Client money

We treat money received into your Revolut Trading investment account as client money where the CASS rules require us to do so.


Your client money may be pooled with client money belonging to our other clients and held in one or more segregated client money bank accounts with an eligible third party. Those accounts are opened in our name but are designated as client money accounts, so that the client money is kept separate from Revolut Trading’s own money.


We maintain records of your individual entitlement to the pooled client money. Pooling means that you do not have a claim to a specific bank account or specific notes or coins. If an eligible third party holding pooled client money fails and there is a shortfall that cannot be recovered in full, clients in the relevant pool may have to share that shortfall proportionately.

3. Diversification

Where practicable, we assess whether to spread client money between different eligible third parties (we call it “diversification”).


Diversification is intended to reduce the potential impact of the failure of any one eligible third party, but it does not fully eliminate that risk. If an eligible third party holding client money becomes insolvent or otherwise fails, there may be delays in recovering client money and there may be a shortfall if the amount recoverable from that third party is less than the amount it should hold for clients.

4. Notice and Fixed Term Deposits

We may hold client money in a client money bank account that has a fixed-term or requires a period of notice before withdrawal, in each case only where permitted by the CASS rules. The applicable fixed-term or notice period will not exceed 95 days. Where we use an account with a fixed term or notice period, we must maintain sufficient accessible money to meet withdrawal requests from our clients during that period because we may not be able to access the money in that account until the notice period has expired or the fixed term has ended.


There are additional risks associated with such accounts. If we or the eligible third party holding your client money were to fail, or if a large number of clients requested withdrawals at the same time, money held in the fixed-term or notice account may not be immediately available for distribution in the same way as money held in an instantly accessible or shorter-term account. During the fixed-term or notice period, we may also be unable to react to adverse information about an eligible third party holding client money by withdrawing the client money held with it, which may increase the risk of loss or reduction in the amount available for distribution.


5. Custody assets

We safeguard the financial instruments held in your Revolut Trading investment account as custody assets in accordance with the CASS rules and keep records showing your entitlement to them. Your financial instruments are held separately from our own assets.


You will remain the beneficial owner of your financial instruments. Legal title will be registered or recorded in accordance with the CASS rules and, depending on the instrument and the custody arrangements through which it is held, may be registered or recorded in the name of Revolut Trading Nominees Ltd (“RTNL”) (a non-trading nominee company controlled by Revolut Trading and established to hold client assets), or another nominee company controlled by Revolut Trading, you, a nominee controlled by another member of the Revolut group, a nominee controlled by a recognised investment exchange, a nominee controlled by an independent third-party custodian with whom the financial instruments are deposited.


Where registration in one of the above names is not possible, legal title to your financial instruments may, where the CASS rules permit, be registered in the name of another third party or in the name of Revolut Trading. This will only occur where:

  • the financial instruments are subject to the laws or market practice of a jurisdiction outside the UK;
  • we consider this to be in your best interests; or
  • it is not reasonably practicable to register them in another way because of the applicable law or market practice.


Where your financial instruments are registered in the name of a nominee, a third party or Revolut Trading, you may not be able to exercise certain rights that would otherwise be available to a registered holder, including, receiving shareholder communications directly, attending or voting at shareholder meetings, or participating in certain shareholder benefits, corporate actions or incentive programmes.


6. Pooling of custody assets

Your custody assets may be held in an omnibus account together with assets belonging to other customers. We maintain records of each customer’s entitlement to assets held in such accounts.

Pooling can create additional risks. Your entitlement may not be evidenced by a separate certificate or other record at the third-party level and, if we or a third-party custodian fails and there is a shortfall in the pooled assets that cannot be made good, you may have to share that shortfall proportionately with other affected clients. There may also be delays while individual client entitlements are identified and reconciled.


7. Stock shortfalls

We perform custody reconciliations designed to identify discrepancies between the custody assets that our records show should be held for clients and the custody assets recorded as being held by us or by a third party we appoint.


If we identify a discrepancy that results in, or reveals, an unresolved shortfall in custody assets, we will investigate and take steps to resolve it without undue delay. Until the discrepancy is resolved, and where required by the CASS rules, we will protect the affected customers by appropriating a sufficient amount of our own money.

An unresolved discrepancy may temporarily affect our ability to receive or process instructions relating to the affected custody assets. We will consider whether it is appropriate to notify affected clients having regard to our regulatory obligations and the circumstances of the shortfall.


If, following the failure of Revolut Trading or a third party, a shortfall remains and cannot be made good in full, affected clients may not receive their full entitlement and may have to share in the shortfall proportionately. Nothing in this summary limits any rights you may have against us, a third party or an applicable compensation scheme.


8. Dormant accounts and unclaimed client assets

Client money or custody assets may become unclaimed where we have been unable to return them to you. The CASS rules permit us, in specified circumstances and after the relevant period has elapsed, to cease treating unclaimed cash or assets as client assets and to pay them, or the proceeds of their sale, to a registered charity.


For client money, we may use this process only where we have held the balance for at least six years following the last movement on your account (excluding payments or receipts of interest, charges, or similar items) and the applicable tracing and other CASS requirements have been satisfied.


For custody assets, we may use this process only where we have held the assets for at least twelve years, have received no instructions from you in relation to those assets during the preceding twelve years, and the applicable tracing and other CASS requirements have been satisfied.


Before taking any action, we will take reasonable steps required by the CASS rules to try to contact you and return the relevant client money and/or financial instruments to you.


For unclaimed client money of £25 or less in aggregate for a retail client, or £100 or less in aggregate for a professional client, the CASS rules permit a simplified process after the same six-year period. Where we use that process, we will make at least one attempt to return the balance using the most up-to-date contact details we hold for you and allow the applicable response period before paying the balance to charity. There is no equivalent monetary de minimis threshold for unclaimed custody assets. Where custody assets remain unclaimed, we may transfer those assets to charity, or liquidate them at market value and pay the proceeds to charity, after the applicable 12-year period and once the relevant tracing and other CASS requirements have been satisfied.


If you later make a valid claim after:

  • client money has been paid away, we will pay you a sum equal to the amount that was paid away to charity;
  • custody assets have been paid away or liquidated and the proceeds paid away, we will pay you a sum equal to the value of those assets at the time they were paid away or liquidated.


9. Use and Oversight of Third Parties

We may, subject to the CASS rules, hold your client assets with suitable third parties, including banks, intermediaries, sub-custodians, depositories and nominees, or appoint third parties to perform functions relating to the safekeeping, custody, execution or settlement of your client assets. Where we do so, we are required by the CASS rules to exercise due skill, care and diligence in selecting, appointing and periodically reviewing such third parties and the arrangements for holding client assets through them.


We accept responsibility for the acts and omissions of RTNL in relation to the custody rules as if those acts and omissions were our own. Subject to applicable law or regulation, and unless we agree otherwise with you in writing, we are not liable for any acts. omissions and/or defaults of any other third parties.


If a third party that holds your client assets fails or becomes insolvent, there may be delays in identifying and recovering your client assets and the amount ultimately recovered may be less than the amount that should have been held for you.


10. Client money and assets held outside the UK

Your client assets may be held outside the UK. This may happen because an eligible third party or sub-custodian we use holds assets in another jurisdiction, or because a transaction is carried out, or income (such as dividends) is received, outside the UK. The applicable local legal, regulatory, insolvency and market arrangements in that jurisdiction may differ from those applying in the UK. As a result, your rights and protections available to your client assets may be different and, in some circumstances, less protective than under the UK law. In particular, a bank, custodian, sub-custodian, exchange, clearing house, broker or other third party outside the UK may have rights over client assets, including a security interest, lien or right of set-off, where applicable local law or market practice allows this, and if such right is exercised it could reduce the amount you get back. Practices for identifying and segregating client assets also differ from those in the UK.


11. Controls and Governance

We maintain systems and controls designed to safeguard your client assets, maintain accurate records of client entitlements and ensure they are used only for purposes permitted by the CASS rules.


Our client asset arrangements are subject to governance and oversight. We have appointed a CASS Oversight Officer with responsibility for oversight of compliance with the CASS rules. The CASS Oversight Officer reports to an Executive Director who has ultimate responsibility and accountability for our client asset arrangements. In addition, our arrangements are subject to periodic monitoring and independent external CASS audit in accordance with applicable regulatory requirements.


Despite these controls, discrepancies may arise, resulting in us holding an incorrect amount of client money or quantity of custody assets. Where a discrepancy results in a client money shortfall, we will take the steps required by the CASS rules to address and segregate the appropriate amount of our own funds in the client money account while the matter is investigated and resolved. Where a discrepancy results in, or reveals, a custody asset shortfall, we will apply the protections described in the “Stock shortfalls” section above.


12. Financial Services Compensation Scheme (“FSCS”)

If Revolut Trading or one of the financial institutions holding client money is unable to meet its financial obligations, you may be entitled to compensation from the FSCS - a government-backed scheme that may pay you compensation if a financial firm fails.


FSCS protection is available to certain eligible claimants and depends on your eligibility, the regulated activity involved and your individual circumstances. Two different types of FSCS cover may be relevant, depending on what goes wrong:

  • If Revolut Trading fails and is unable to return your money or instruments that it holds for you in connection with investment business, eligible claimants may be entitled to FSCS protection up to the applicable statutory limit (currently £85,000 per eligible person, per firm, subject to the FSCS rules and any future change).
  • If a UK-authorised bank or deposit-taker holding your client money fails, eligible depositors may be entitled to FSCS deposit protection up to the applicable statutory limit (currently £120,000 per eligible depositor, per authorised deposit-taker, subject to the FSCS rules and any future change). Where client money is held in a pooled account, eligibility and compensation depend on, among other things, the deposit-taker being a UK-authorised institution covered by the FSCS and our records being sufficient to identify each client’s individual entitlement. The £120,000 deposit protection limit generally aggregates with any deposits you hold directly with the same bank or banking group in your own name, i.e. the £120,000 limit applies to everything you hold there together and not to each account separately.

The FSCS determines eligibility and compensation in accordance with its own rules. If your claim is approved, the FSCS will pay compensation directly to you.


It is important to note that the FSCS protection does not protect you against ordinary investment losses (for example, losses caused by the normal fluctuation of the stock market). It only protects you if a firm fails and your assets are lost.


Further information, including current compensation limits, eligibility criteria and how to make a claim, is available on the FSCS website. You can also use the FSCS Investment Protection Checker to understand whether your investments may be covered.


Telephone: 0800 678 1100 or 020 7741 4100

Website: www.fscs.org.uk


13. Further information

Any information contained in this summary does not have the effect of limiting any rights you may have under the applicable laws or regulations in any way.


If you have further questions about how your money or assets are protected, please contact Client Support via the Revolut App.