Custody of customer assets
Custody of customer assets in Healthcare & Life Sciences sits at an underappreciated crossroads: patient financial data, prepaid care balances, and health savings account structures are drawing scrutiny from the U.S. Department of Health and Human Services Office for Civil Rights, the Consumer Financial Protection Bureau, and state-level insurance commissioners who are pressing hard on how healthcare entities hold, segregate, and disclose funds they control on a patient's behalf. The CFPB's 2023 Personal Financial Data Rights rulemaking, finalized under Section 1033 of Dodd-Frank, is pulling health-adjacent financial products directly into a custody disclosure framework that most life sciences compliance teams have not mapped yet.
Watch
- CFPB Section 1033 final rule: applicability to HSA and FSA custodians in 2025
- HHS Office for Civil Rights guidance on financial data commingling with protected health information
- State insurance department segregation requirements for prepaid health plan reserves
- Vendor escrow and asset-holding clauses in pharma patient assistance program contracts
Recent material activity in Healthcare & Life Sciences
Active monitoring in place across Healthcare & Life Sciences. Material developments related to custody of customer assets will appear here as they are published.