Two special administrations in 48 hours: client-asset risk returns to the boardroom

Two FCA-authorised firms collapsed into special administration inside 48 hours this week. Jarvis Investment Management Limited entered the regime on 14 October 2026, with Adam Stephens and Philip Hemming of S&W Partners LLP appointed as special administrators (FCA). The next day, ePayments Systems Limited followed, with Mark Boast and Allister Manson of Opus Restructuring LLP taking over an e-money issuer regulated under the Electronic Money Regulations 2011 (FCA). Different business models, different insolvency regimes, same board-level question: who really controls, and compensates, client funds when the music stops.

Different regimes, same pressure point

Jarvis had been operating under a voluntary requirement agreed with the FCA on 16 September 2022 that restricted the activities it could undertake without FCA consent (FCA). That the firm still reached special administration four years later is a reminder that voluntary requirements buy time, not resolution. For wealth managers and platforms that rely on Jarvis-style custody or dealing arrangements, the practical issue is immediate: clients cannot trade or otherwise use custody assets or client money held with the firm until the special administrators complete their assessment (FCA). Advisers whose underlying custodian has failed will field the calls, regardless of where contractual responsibility sits.

The ePayments case cuts a different way. The Payment and Electronic Money Institution Insolvency Regulations 2021 created a bespoke regime with the explicit objective of returning customer funds as soon as reasonably practicable (FCA). But the FCA is blunt that the FSCS does not cover payment services, and customers depend on the firm's safeguarding arrangements (FCA). Boards of payments firms, and the banks that provide their safeguarding accounts, should expect renewed FCA attention to reconciliation quality, segregation evidence and the speed at which a trustee or administrator could identify what belongs to whom.

The outsourcing question boards keep deferring

Most firms that will feel the Jarvis fallout are not Jarvis clients directly. They are IFAs, discretionary managers and platforms whose end-investors sit, often invisibly, behind a chain of nominee and custody arrangements. The special administrators have asked clients to speak to their financial adviser or wealth manager in the first instance (FCA). That operational burden lands on firms that did not choose the insolvency and may not have modelled it. Consumer Duty obligations do not pause while an administrator reconciles a CASS estate.

For payments and e-money groups, the equivalent exposure runs through BIN sponsors, principal-agent relationships and safeguarding banks. Each ePayments-style failure tests whether the written safeguarding methodology survives contact with real-time insolvency. Senior leaders who cannot produce, on demand, a current map of where customer funds sit, which entity holds legal title, and how quickly a court-appointed administrator could release them, are carrying a risk their auditors and non-executives should already be pricing.

Two administrations in a week do not constitute a trend. They do, however, hand every board a free rehearsal. The firms that use it will be ready for the next one.