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The Broker Desk

Forex & CFD brokerage

--:-- Local Monday 31 August 2026
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2026
25 Aug Comparison · 8 min PAMM and MAM Account Structures: Regulatory Risk for Brokers The regulatory risk in a PAMM or MAM product is not the software that allocates trades. It is the classification of the arrangement itself, decided by two facts: who holds discretion over client money, and whether client funds are pooled. A PAMM, where client money sits in a single master account traded under one manager's power of attorney, maps onto the statutory definitions of a collective investment scheme under UK law (FSMA 2000, s.235) and of a commodity pool under US law (CFTC Regulation 4.10(d)(1)). A MAM, where each client keeps a separate account, avoids the pooling test but is discretionary management of client portfolios — a licence-triggering activity in the UK and EU, and, in Australia, an arrangement ASIC says can constitute a managed discretionary account regardless of its terminology. For a forex or CFD broker the consequence is commercial: sell a managed-account product through an entity licensed only for dealing and execution, and the exposure comes from the structure, not the code.