Can we keep our bank while we test a new FX provider?
Yes, and you should. Nothing at your bank needs to close. Your client bank accounts, premium receipts and claims payments carry on exactly as now while the new provider proves itself on small payments.
Opening an account with a specialist provider changes nothing at your bank. The new account is used first for test payments, then for one real flow, then for the rest. The old route stays live throughout, so any flow can go back to it if a test fails.
Before you start, find every place your current bank details are written down. Binding authority agreements, terms of business agreements with insurers, debit note and invoice templates, standing settlement instructions held by markets and the payment set-up in your claims system may all carry them. That list becomes your update plan later.
Flows that settle through Lloyd's central accounting and settlement are converted there according to managing agents' standing instructions, and they are not part of a switch. This plan is for the flows that run through your own bank accounts.
A second live route also limits the damage if a provider fails. Argentex LLP, an FCA-authorised payment and e-money institution with FX clients, entered special administration on 21 July 2025. Firms that already had a second provider onboarded had somewhere else to send their payments while the administration ran.
What does a staged switching plan look like?
Seven stages over roughly 12 to 16 weeks: baseline, settlement calendar, quotes, compliance sign-off, onboarding, testing, then moving flows one at a time and reviewing the result.
| Weeks | Stage | What happens | Check before moving on |
|---|---|---|---|
| 1 to 2 | Baseline | A cost review of 6 to 12 months of conversions: markup to mid by flow, pair and size band, plus receiving charges, intermediary bank deductions and service problems. | You know what you pay now in basis points and what the switch has to beat. |
| 1 to 3 | Settlement calendar | Every fixed date for the next six months listed: binder remittances, quarter-end premium accounts, reinsurance settlements and cash calls, claims runs and the month-end client money calculation. | Finance, credit control, claims and compliance have agreed the calendar and the weeks when nothing moves. |
| 2 to 4 | Blind quotes and shortlist | Your real flows priced by several providers without your firm's name. Rates, charges, cut-offs, payment reach and onboarding times side by side. | A shortlist of one or two providers, with the reasons written down. |
| 3 to 8 | Compliance sign-off and due diligence | Client money position agreed for each flow. The provider's FCA status, safeguarding method and ownership checked. Binder and TOBA terms reviewed for named accounts or currencies. | Written sign-off from your compliance officer, with your CASS auditor's view where your compliance officer wants it. |
| 4 to 10 | Onboarding | The provider runs its own checks with your firm and opens accounts in the right entity names. Users, roles, limits and approval rules set up. | Accounts open, controls tested and statements available in a format your reconciliation can use. |
| 8 to 12 | Test | Small test payments in each currency, then a handful of small claims payments and supplier payments. The old route stays fully open. | Each payment arrived on the value date, in full, with the right reference and beneficiary name, and the claim file holds its confirmation. |
| 10 to 16 | Move and review | Flows moved one at a time, lowest risk first, never in the week of one of their fixed dates. The first quarter end on the new route reviewed against the baseline. | Markup and service match the quote, the client money reconciliation is clean, and the old route stays open until nothing more arrives there. |
Firms with several entities, many coverholders or a large client money book often take longer at the compliance and onboarding stages. Nothing in the plan needs your bank account to close early, so a slow stage delays the move rather than a settlement.
In what order should we move premiums, remittances and claims?
Start with your firm's own money and the flows with no fixed date. Leave premium collection and remittances to capacity until the new route has proved itself and compliance has signed off.
Expenses and supplier payments
Your firm's own money, paid in other currencies: overseas offices, service companies, loss adjusters' fees, software and data. A missed cut-off here is an inconvenience, not a breach of a binder.
Commission and brokerage conversions
Converting your own income to sterling. A good early test of how the provider prices regular flows once the account is live.
Claims payments
Start with small payments in your main claim currencies, then larger ones and less common currencies. If the claims money is client money in your hands it waits for the compliance sign-off like any other client money flow.
Reinsurance premiums and recoveries
Moved outside settlement weeks and away from the main renewal dates, with the old route kept live for any cash call.
Premium conversions and remittances to capacity
Last, and only once your compliance officer has signed off the client money position for those flows and the capacity providers' receiving details have been confirmed through their own verified process.
Which settlement dates can we not miss during a switch?
Binder remittance dates, quarter-end premium accounts, reinsurance account settlements and cash calls, claims payment runs and your month-end client money calculation. List them for the next six months before you move anything.
| Date | When it falls | Check during the switch |
|---|---|---|
| Binder remittance dates | Set in each binding authority agreement, for example a number of days after the end of the bordereau month | Do not move remittances in the fortnight before one is due. Confirm the capacity provider's receiving details through its own verified process, never from an email. |
| Quarter-end premium accounts | The end of each quarter, when broker and market accounts are agreed and settled | No changes to premium routes in the last two weeks of a quarter. Reconcile both routes at quarter end. |
| Reinsurance account settlements and cash calls | As set in each contract, often quarterly, with cash calls payable within the period the contract allows after a large loss | Keep the old route live and funded for the whole switch so a cash call can be paid from either route. |
| Claims payment runs | Daily or weekly runs, plus urgent one-off payments | Test each claim currency before moving it. Agree who can release an urgent payment on each route. |
| Month-end client money calculation and reconciliation | Month end, or the frequency your firm uses | The new provider's statements arrive in time and in a usable format, and compliance has agreed how converted amounts are treated, before the first live conversion. |
| Main reinsurance renewal dates | 1 January, 1 April, 1 June and 1 July | Avoid moving reinsurance flows in the weeks either side, when premium volumes peak. |
| Year end and audits | Your financial year end and your CASS audit period | Keep the switch out of the weeks when finance and the auditors are busiest. |
Put the dates in one shared calendar with an owner for each. The rule is simple: a flow never moves in the same week as one of its own fixed dates, and the old route stays open until the next date has passed cleanly on the new one.
How do we update collection details with insureds, coverholders and markets safely?
Only through channels they already trust, with verification by phone on a number they already hold. Payment diversion fraud is the main risk in any switch, and InsuranceFX never sends payment details.
First check whether the details need to change at all. Before any premium collection details point to a new account, your compliance officer must confirm how that account fits your client money position. CASS 5 generally requires client money to be held in a client bank account at an approved bank, so for many brokers and MGAs the collection details may not change. Our page on client money, CASS 5 and FX sets out the questions to ask.
Where details do change, fraudsters watch for exactly that moment. A switch gives them a reason to send a convincing email with new bank details, so every change goes out in a form they cannot easily copy:
- Producing brokers and coverholders: a letter on your letterhead signed by an authorised person, sent by post or through the secure portal you already use, asking them to confirm by calling a number from their own records.
- Insureds: new details on the debit note or invoice only after test receipts have arrived, with a printed line saying you will never change bank details by email.
- Insurers and capacity providers: if they pay you claims, recoveries or commission, their standing settlement instructions for you are updated through their own verification process. If you pay them, their details do not change, so treat any message saying otherwise as suspect.
- Reinsurers and reinsurance brokers: new settlement instructions from the next account onwards, through the broker's verified process, not in the middle of an account.
- Claims payees: claimants' and suppliers' bank details confirmed from your claim file records. Any request to change them during the switch is suspect until verified by phone.
- The old account: keep it receiving until nothing more arrives there, and agree with compliance how late payments to it are handled.
Record who approved each change, when and how it was verified. Your auditors and your capacity providers may ask.
InsuranceFX never sends, receives or changes payment details for anyone. If someone claiming to be InsuranceFX asks you or your counterparties to change bank details, do not act on it and call us on 020 7566 0044.
What does our compliance officer need to sign off before we switch?
The client money position for every flow that will move, the provider's regulatory status and safeguarding, and any binder or TOBA terms that name an account or a currency.
- Which flows are client money, which are held under risk transfer and which are your firm's own money, flow by flow.
- Whether any client money flow can use the new provider at all, and on what basis. That is for your compliance officer and CASS auditor to decide. Neither InsuranceFX nor the provider can decide it for you.
- The provider's FCA authorisation type and firm reference number on the FCA Register, and how it safeguards customer money.
- Binding authority agreements and terms of business agreements that name a bank, an account or a settlement currency, and whether capacity providers or insurers need to be told.
- How the provider's statements will feed your client money calculation and reconciliation.
- Sanctions. The provider screens the payments it makes. Your firm keeps its own sanctions obligations as an insurer, broker or claims handler, including for the people and firms you pay claims to. The Office of Financial Sanctions Implementation publishes the official guidance.
- Board or committee approval where your governance requires it, with the sign-off recorded.
Which approvals and payment controls need setting up on the new account?
At least the controls you have today, set up before the first live payment: two-person approval, beneficiary approval, limits that match claims authority and a full audit trail.
- Dual authorisation for every payment and conversion, with limits by user and by amount.
- Payment limits that mirror your claims authority levels, so nobody can release a payment on the new route that they could not approve on the old one.
- Separation between the people who set up claims payees and the people who approve payments.
- Beneficiary approval, so a new payee needs a second person before money can go to it.
- Strong sign-in for every user, and leavers removed on the day they go.
- Payment confirmations with references your claims system and claim files can hold.
- Statements in a format credit control and the client money reconciliation can load without rekeying.
- A named contact at the provider and an escalation route for a payment stuck on a settlement date.
What does InsuranceFX do at each stage of a switch?
We do the comparison and the organising. The provider does everything that touches money. Your firm makes the decisions and keeps responsibility for its client money compliance.
| Stage | InsuranceFX | The provider | Your firm |
|---|---|---|---|
| Baseline | Runs the cost review and writes it up | Not involved | Shares redacted statements |
| Settlement calendar | Helps build the calendar from your list of dates | Not involved | Confirms every date and the weeks when nothing moves |
| Quotes | Puts your flows to several providers without your firm's name | Prices the requirement | Chooses whether to go further |
| Compliance and due diligence | Collects dated facts on authorisation, safeguarding and ownership | Answers questions and provides documents | Decides the client money position and signs off |
| Introduction and onboarding | Makes the introduction through Introvisory Ltd and coordinates timings and checklists | Runs its own checks directly with your firm | Provides documents to the provider |
| Testing and moving flows | Tracks progress against the settlement calendar. Never touches money or payment details | Executes conversions and payments and safeguards funds | Instructs and approves every payment and updates counterparties |
| Review | Compares results with the baseline and re-quotes your main flows once a year | Provides statements | Decides whether anything changes |
Many firms come to us because their rate has crept up since they signed. Our guide to FX rate creep shows how to check. MGAs will find binder-specific detail on our page for MGAs and coverholders.
Ask for a cost review Request a blind quote
Sources
- Financial Conduct Authority, Argentex LLP enters special administration, checked 2 November 2026.
- Lloyd's, Foreign exchange (Currency Conversion Service within Central Accounting and Settlement), checked 2 November 2026.
- HM Treasury, Office of Financial Sanctions Implementation, checked 2 November 2026.