ITI Capital and the Real Cost of a Slow Wind-Down

On 25 September 2026 the FCA confirmed that ITI Capital Ltd had entered special administration. Duncan Perring and David Soden of Teneo Financial Advisory have been appointed special administrators. The headline is a small London brokerage failing. The real story is the 13 months before it.

What happened

ITI Capital was an FCA-authorised brokerage based on Threadneedle Street, offering share and bond investing and holding client money and custody assets. On 10 August 2025 it agreed with the FCA to stop most regulated activity and to stop accepting new client money or custody assets. For just over a year the firm sat in that state. It then entered special administration under the Investment Bank Special Administration Regulations 2011, the modified insolvency regime for investment firms that hold client assets.

The special administrators' first objective is to return client money and custody assets as soon as they reasonably can. Clients will hear from them within eight weeks, and the FSCS may cover eligible clients up to £85,000. The FCA has also been clear that the costs of distributing client assets may be deducted from what clients get back if there are not enough funds to cover them.

Why the gap matters

Public records show no disclosed trading loss or capital breach. We do not actually know what happened inside the firm during those 13 months, but the more likely reading of a year long gap between stopping new business and formal insolvency is an attempted solvent exit or sale that did not complete. If that is the case, that is in effect an unplanned wind-down. What we do know is that a long gap between stopping new business and formal insolvency is exactly the situation a wind-down plan is meant to prevent.

A wind-down plan that only works if a buyer turns up is not a wind-down plan.

The FCA expects every firm holding client assets to plan for an orderly exit, through its Wind-down Planning Guide and the CASS resolution pack. In our experience most firms treat both as compliance documents, they are written once, filed, and refreshed annually. They are rarely tested against the one question that matters .... if we stopped trading tomorrow, how long would it take to return every client's money and assets, and who would pay for it?

The cost lands on clients

This is the part of the regime clients rarely understand and firms rarely explain. When a special administration runs, the cost of returning assets can fall on the client pool. A clean, reconciled client asset book shortens the process and cuts that cost, a messy one extends it. The quality of a firm's CASS records is, in fact, a direct measure of how much its clients stand to lose on the way out.

Five questions for the board

We would suggest boards of platforms, brokers, DFMs and wealth managers put these on the agenda this quarter.

• Does our wind-down plan have a realistic timeline, cost and funding source that does not depend on a sale?
• Could we produce a complete CASS resolution pack within 48 hours, and have we actually tried?
• Are client money and custody reconciliations clean, with every break aged and explained?
• Have we set clear trigger points at which the board moves from recovery to wind-down?
• Where we rely on a third-party custodian or platform, what does our due diligence say about that provider's own wind-down plan?

The last question matters as much for advisers and DFMs as it does for the custodian. Client assets sit with the provider you yourself chose. Consumer Duty expects you to understand the risks your customers face across the distribution chain, and provider failure is one of them.

Where Trescore fits in

We have run platforms and brokerages, and we have sat on the boards that sign off these plans. We help firms turn wind-down plans and CASS resolution packs into working documents, test them properly, and carry out provider due diligence that goes beyond the questionnaire. This is not legal or insolvency advice, and we do not position it as such.

If ITI Capital has prompted a conversation in your boardroom, get in touch with your Trescore contact.