Client fund safeguards require investment thresholds, segregated holdings, transparent account records, fiduciary conduct, and prohibit borrowing for clients.

An FME must observe a minimum investment threshold for portfolio management clients, subject to an exemption for accredited investors. Client funds may be held through specified FME, client, or regulated broker-dealer accounts, subject to operational authority, compliance controls, and disclosure of account and transaction details when directed. Client securities must generally be segregated, with omnibus structures permitted only with prior client consent and separate earmarking. The FME must accurately record client account movements, act in a fiduciary capacity, avoid benefiting from client assets, and not borrow on a client's behalf.

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