Regulatory Roundup 23 contained an article on changes to CASS and the need for affected firms to complete a Client Money and Asset Return (CMAR).
The FSA has released CP11/4 – ‘The Client Money and Asset Return (CMAR): Operational Implementation’ – which includes an example of the final version of the CMAR together with guidance as well as advising of a postponement in the reporting obligations of ‘small’ CASS firms(see below).
The consultation is in two part parts; for CASS ‘medium’ and ‘large’ firms the consultation closes 10 April whilst for ‘small’ firms the period is shorter – 10 March. The definitions of large, medium and small are contained in CASS 1A.2.7 and are dependent upon the highest amount of client money/safe custody assets held.
The CMAR will be submitted via GABRIEL but, for now, only in respect of large and medium CASS firms. Small CASS firms will be subject to a notification requirement to the FSA as an interim measure. The FSA will introduce the CMAR for small CASS firms ‘as soon as is practicable’. The FSA will contact all such firms requesting this information.
Reporting will be monthly for medium/large firms and half-yearly (to 30 June & 31 December) for small firms. Details have to be submitted within 15 business days meaning that the first notification/CMAR is due by Thursday 21 July. Annex 3 of CP11/4 contains a useful summary. From 1 October the CF10a function (see Regulatory Roundup 23 for further information) will be required to take responsibility for completing and submitting the CMAR.
