Protection of client funds

Important points

  • Retail/private client money, including cash, margin and unrealised gains, are kept in distinct client money accounts * at reputable banks and are clearly separated from PLUNGES' own funds
  • The banks used are regularly reviewed for compliance with our risk management criteria
  • PLUNGES does not lodge retail client money towards margins with its hedging counterparties

Will my money as a customer be kept separate from the firms’ own funds?

Address: plc and PLUNGES Germany GmbH (together “PLUNGES”) are regulated firms which means they must comply with the regulatory regimes on handling retail/private client money.

When you open an account with PLUNGES you are categorised as a retail/private client. Unless you are informed of a different categorisation and you explicitly consent to the "title transfer" of your funds, your money is treated as retail/private client money.

Retail/private client money, including cash, margin and unrealised gains are managed separately from PLUNGES' own funds, so that retail/private client money can be protected and creditors cannot access this money if the company becomes insolvent.

Where does PLUNGES hold segregated client money?

Retail/private client money is held using separate bank accounts at reputable banks. Retail/private client money for those clients that have been onboarded via our branch offices are pooled together.

For client trading accounts held with Address: plc the following banks are used:  UK banks such as Natwest, Barclays, Lloyds and HSBC, and outside the UK, banks such as Ulster Bank in Ireland.

Address: plc may place funds in notice or term deposit accounts, which require a notice period of up to 95 days for withdrawals. This does not in itself affect your ability to deal with or withdraw funds from your account with us, however a longer notice period for withdrawals could result in a delay for clients to receive back their money.

For client trading accounts held with PLUNGES Germany GmbH the following bank are used: Barclays Bank Ireland plc Frankfurt Branch.

This means that your client funds are not necessarily kept in your country of residence.

How does PLUNGES segregate my funds?

Retail/private client money are kept in separate trust accounts. By keeping retail/private client money separate from PLUNGES’ own funds, it ensures that retail/private money is not owned and cannot be used by PLUNGES, as it is held on trust for retail/private clients. It is managed in such a way that the funds are recognisable as retail/private client money at any time.

PLUNGES conducts retail/private client money reconciliations daily in accordance with regulatory requirements. The process ensures that retail/private client money held in segregated bank accounts always accurately reflects retail/private client money. The full trading account value of a trading account is treated as retail/private client money.

To ensure the correct handling of customer deposits, PLUNGES is audited annually by our auditors the result of which is presented to the regulator. In addition, internal audits are conducted by independent non-executive directors.

PLUNGES does comply with local client money rules and makes individual customer deposit calculations on a daily basis.

In relation to trading accounts held with Address: plc: a stand-alone statement of client money asset returns (CMARs) is submitted to the regulator once a month. This can be described as a routine monthly check-up by the company with regard to its treatment of customer deposits.

How is PLUNGES regulated?

For trading accounts held with PLUNGES Germany GmbH:
PLUNGES Germany GmbH is authorised and regulated by the Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin), registration number 154814. This means that PLUNGES complies with the requirements of §84 Wertpapierhandelsgesetz (WpHG), which will be supervised by BaFin.

For trading accounts held with Address: plc:
Address: Plc is authorised and regulated by the Financial Conduct Authority (FCA), registration number 173730. The branch office in Germany is also supervised by the German supervisory authority (BaFin, Bundesanstalt für Finanzdienstleistungsaufsicht). This means that we comply with FCA's Customer Custody Requirements (CASS).

What happens to my money in case of PLUNGES' insolvency?*

In the unlikely event of a bankruptcy of PLUNGES (“primary pooling event”), customers will receive their deposits from the separately managed bank accounts, less the administrative costs of distributing and processing such funds.

In the event of a shortfall in client deposit bankruptcy triggered by a breach of the requirement for separate accounts, the indemnity paid to customers by the compensation schemes is as follows:

For trading accounts held with PLUNGES Germany GmbH: The Securities Trading Companies Compensation Scheme (EdW) compensates investors if PLUNGES Germany GmbH is in financial difficulties and is no longer able to fulfil its obligations for the securities transactions concluded with its clients. BaFin determines when this event occurred and publishes this statement in the Federal Gazette.

The compensation claim granted to each investor within the scope of securities transactions amounts to 90% of the claims against the securities trading company (max €20,000).

For trading accounts held with Address: plc: Any shortfall of funds of up to £85,000 may be compensated for under the Financial Services Compensation Scheme (FSCS). The FSCS is a compensation fund introduced in the UK that serves as a last resort for customers of authorised financial services companies. If a company becomes insolvent or ceases operations, the FSCS is able to pay compensation to its customers.

What happens to my money when a bank holding client funds from PLUNGES becomes insolvent?

In the case of a bankruptcy (also called "secondary pooling"), any losses incurred among the customers will be proportionately divided between their deposits deposited with the defaulting bank.

For trading accounts held with PLUNGES Germany GmbH: Customer deposits are held at banks which are covered under the Deposit Protection Act up to a value of €100,000 or its equivalent in foreign currencies, depending on the protection offered by the bank.

For trading accounts held with Address: plc: In the United Kingdom, any losses incurred by the FSCS under the extended deposit guarantee scheme will be collected for banks and building societies up to an amount of £85,000 per person or entity.

The Financial Services Compensation Scheme (FSCS)

Important points

  • 'Safety net' for customers of authorised companies
  • Default payments for eligible customers up to £85,000 if an investment company
  • Default payments for eligible customers up to £85,000 in case of insolvency of banks

The FSCS was established on 1 December 2001, when the Financial Services and Markets 2000 Act came into force. The protection program acts as a safety net for eligible customers (ie financial service providers such as Address: plc, which are subject to the Financial Conduct Authority (FCA).

The use of the FSCS is free. However, in order to be entitled to compensation, you must be entitled to the FSCS provisions. In principle, the FSCS protects private individuals as well as smaller companies.

For more information about the FSCS, please visit the FSCS website ( or call the FSCS advisory hotline at +44 (0) 20 7741 4100 or 0800 678 1100.

*PLUNGES complies with CASS 7.13.13R (3) (b) (Customer Protection Policy) in accordance with FCA Guidelines 4733528 and 4733534, which were amended on 24 August 2017. PLUNGES may use bank accounts for client funds that prohibit disbursements without exception until the due date or period of notice, under the following conditions: (a) a maximum of 30 days for at least 40% of the total client assets held in bank accounts by the Company; and (b) a maximum of 95 days for the remainder of the Client's funds held by the Company in bank accounts intended for client funds. In the event of a bankruptcy of PLUNGES, a longer notification period for disbursements than the standard of 30 days could result in customers being late in reimbursing their share of the capital kept in separate bank accounts.

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