Investor compensation schemes: who pays when the firm cannot

Investor compensation schemes: who pays when the firm cannot
Short answer

An investor compensation scheme is a pooled fund, usually financed by levies on licensed firms, that pays a capped amount to clients when one of those firms fails and cannot return their money or assets. It covers the failure of the firm, not the performance of your trades. Eligibility depends on which legal entity holds your account and whether that entity is a member of the scheme, which is not always the entity whose brand is on the website.

An investor compensation scheme is a pooled fund that pays you a capped amount if the firm holding your money collapses and cannot give it back. It is insurance against the firm failing, not against your positions losing.

That distinction is the whole subject. Almost every misunderstanding about these schemes comes from blurring two very different events: the firm breaking, and the market moving against you. A scheme addresses the first and has nothing at all to say about the second.

Why a pooled fund exists in the first place

When you deposit money with a venue, you stop holding cash and start holding a claim. The firm owes you a balance. Whether that claim is worth anything depends on whether the firm can honour it, which depends on how the firm is run, how it keeps records, and whether anyone has helped themselves to the pot.

Normal insolvency law handles this badly for retail clients. An insolvency practitioner has to identify whose money is whose, from the failed firm’s own records, and then distribute what remains. If the records are good and the money was properly separated, clients get most of it back, slowly. If the records are a mess, or the money was mixed with the firm’s own, the shortfall is real and it is shared out proportionally. Either way the process takes a long time, and the client has no way to influence it.

A compensation scheme is a shortcut around that. Licensed firms pay levies into a common fund as a condition of holding a licence. When one of them fails, the fund pays eligible clients directly, up to a limit, and then stands in the client’s place as a creditor in the insolvency. The scheme recovers what it can, later, on its own time.

Two things follow from how it is funded. First, cover is capped, because the surviving firms funding the pool cannot be exposed to unlimited liability from a competitor’s collapse. Second, cover is per person per firm, not per account, because the levy model prices failure by firm.

What the scheme actually responds to

A claim turns on one question: is money or property that the firm was supposed to be holding for you now unavailable because the firm failed? If the answer is yes, that is the event the scheme was built for. Shortfalls in segregated client money, assets held in custody that are not there, balances owed and unpaid at the point of collapse.

What it does not respond to is anything that is just the market working. Suppose, purely as made-up numbers, you hold a position worth $4,000 and the market moves against you until it is worth $1,500. You have lost $2,500. Nothing has gone wrong with the firm’s custody of your money: your account correctly shows $1,500 and the firm can pay you $1,500 on request. There is no shortfall, so there is no claim. The scheme would not pay a cent of that $2,500, and it was never intended to.

Now change one fact. Keep the position at $4,000, with the market flat, and have the firm fail with a shortfall in client money. Say, again as an invented figure, the scheme’s cap is $20,000 per person per firm. Your $4,000 claim sits well under that cap, so in principle the scheme can make you whole. Raise the balance to $60,000 against the same invented $20,000 cap and the arithmetic changes shape: $20,000 comes from the scheme, and the remaining $40,000 becomes an ordinary claim in the insolvency, worth whatever the estate eventually pays out on each dollar. Those made-up numbers are there to show the method, not to describe any real limit.

This is why caps matter more as your balance grows. Below the cap, the scheme is close to a guarantee. Above it, your protection is diluted in proportion to how far above you sit.

Here is the part people get wrong, and it is specific.

A trading brand is not a company. It is a name that one or more companies trade under. A single app, with one logo and one sign-up flow, can route clients to different legal entities depending on where they live, which product they asked for, or simply which entity had capacity when they registered. Those entities can hold different licences, or none. Only some of them are members of a compensation scheme.

So the mistake is reading a scheme logo or a licence number in a website footer and concluding that your account is covered. The footer often lists every entity in the group. Your cover depends on exactly one of them: the entity named as the counterparty in the client agreement you signed. If that agreement names an entity in a jurisdiction with no scheme, the scheme mentioned elsewhere on the site is not yours. Nothing about the interface will look different. The onboarding, the platform, the support chat and the branding are identical either way.

The practical version of this check is short:

  1. Open the client agreement or terms you accepted, not the marketing pages.
  2. Find the named counterparty: a company name, a company number, a registered address.
  3. Check whether that specific named entity, not its parent and not its sibling, claims scheme membership.
  4. Check what product you are actually trading, because membership can cover some instruments at that entity and not others.

A second, related error is assuming the scheme pays automatically and quickly. It generally does not pay until the firm has been formally determined to be in default, which is a decision the scheme makes on its own timetable after the failure. The protection is real, but it is not a same-week refund.

How to reason about it next time

Treat a compensation scheme as one layer in a stack, not as a verdict on whether a firm is safe. Segregation is supposed to keep your money out of reach of the firm’s creditors. Capital requirements are supposed to make failure less likely. A scheme is what catches you when the first two did not hold. Checking only the last layer tells you what happens after things break, not how likely they are to break.

And when the balance in an account grows past the point where a cap would make you whole, the cap stops being the main safeguard. From there, what protects you is spreading the balance across entities, or not leaving it sitting with a venue at all. See also our notes on segregated client money, what a regulated broker actually means, and the pre-trade checklist.

Education only, not financial advice. Trading carries a risk of loss.

Key facts

  • A compensation scheme pays out on firm failure, meaning the firm cannot return client money or assets it was supposed to be holding.
  • It never pays out for trading losses, because a losing position is the client's own market risk, not a shortfall in the firm's custody.
  • Funding typically comes from levies on member firms, so the pool is finite and payouts are capped per person per firm.
  • A claim normally only opens after the firm is formally declared in default, which is a determination the scheme makes, not the client.
  • Cover attaches to the licensed legal entity that holds the account, not to the brand, the app, or the group of companies behind it.
  • A single brand can operate several entities with different cover, so two clients of the same app can have different protection.

Frequently asked

Does a compensation scheme cover me if my trades lose money?

No. The scheme exists to replace money and assets the firm was holding for you and cannot return. A losing position is the outcome of market risk you chose to take, so it falls outside the scheme entirely. This is true even if the loss was large and even if the platform behaved badly, as long as the firm is still solvent and can settle your balance.

How do I know which entity actually holds my account?

It is stated in the client agreement you accepted at sign-up and usually repeated in the footer of the website and in the small print of the account statement. Look for a company name, a company number, and a registered address rather than the brand name. The brand is marketing. The entity is the counterparty, and it is the entity that is either a scheme member or not.

Why are payouts capped instead of covering the full balance?

Because the scheme is funded by contributions from surviving member firms, not by an unlimited guarantee. A cap keeps the total liability predictable enough for firms to fund and for the scheme to remain solvent when a large firm fails. The practical consequence is that cover is designed to make small and medium accounts whole, not large ones.

If my funds are segregated, do I still need a compensation scheme?

Segregation and compensation solve different parts of the same problem. Segregation is meant to keep client money legally separate so it is not available to the failed firm's creditors. A compensation scheme is what covers the gap when segregation fails in practice, for example because records were poor, money was commingled, or some of it is simply missing.

Risk warning: trading is high risk and most retail accounts lose money. Education only, not financial advice.

Run the numbers