A look at the books

The short answer to the question 'does it matter' is yes. Your application for authorisation by the Financial Services Authority was accepted on the basis that you had confirmed you would have all the processes in place by January of last year.

You have not mentioned the type of bank account. The FSA will expect you know precisely which firms give you risk transfer and which do not.

I hope you are performing your client money calculation every 25 business days, and keeping the evidence that you have done so.

Are you reconciling your client balances with the calculation, and ensuring that surplus funds are removed from the client account? Are you able to track, insurer and insurer, the situation with premiums paid, has commission been withdrawn, for example, and extended this to include any other brokers you might place business?

The FSA did find some areas of concern when carrying out some thematic work on brokers' cash handling arrangements. Rectify any problems now, or find yourself in some difficulty. Your trade body may be able to give you some guidance, or recommend a firm to come and help you.

You are not alone. The key is to rectify now, as the consequences of not doing so will outweigh any short term gain of 'getting away with it'.