The Client Money and Assets (CASS) Blueprint: For CASS 6 & 7 Firms

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firm must not keep money in respect of which any one of the following chapters applies in the same client bank account or client transaction account as money in respect of which another of the following chapters applies: MIFIDPRU 5 Annex 1 Notification under MIFIDPRU 5.6.3R and 5.9.3R that limits for concentration risk have been exceeded These specific requirements in CASS relate to fundamental components of the regime and firms should continue to make any notifications required under CASS. CASS firm classification

COBS 22.3 Restrictions on the retail distribution of contingent convertible instruments and CoCo funds

SUP 16 Annex 49A General insurance pricing information report forms (REP 021, REP021a, REP021b, REP021c, REP021d and REP021e) MIFIDPRU 2 Annex 5 Application under MIFIDPRU 2.5.34R(2) for permission to use offsetting positions when calculating K-NPR on a consolidated basis MIFIDPRU 1 Annex 3 Notification under MIFIDPRU 1.2.13R(2)(b) that a non-SNI investment firm qualifies to be reclassified as an SNI investment firm MIFIDPRU 8 Annex 2R Disclosure template for information required under MIFIDPRU 8.7.1R in respect of voting rights SUP 12.4 What must a firm do when it appoints an appointed representative or an FCA registered tied agent?

The FCA has invested significant effort in enhancing protection for client assets. CASS is regularly updated and the FCA has also carried out active supervisory work on how firms are implementing requirements to protect client assets.

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Small firms do not need to complete the CMAR. Although they should have a suitably experienced person looking after CASS compliance, this does not need to be a director or pre-approved senior manager. Why is compliance with CASS so important to the FCA? SUP 10C Annex 6R Form D: Notification: Changes to personal information/application details and conduct breaches/disciplinary action related to conduct acting as trustee or depositary of a UK UCITS 9 and in this case also include any safe custody investments to which the firm is required by CASS 6.1.16IDR to apply the custody rules under CASS 6.1.1BR(3) 7; and 6 FEES TP 9 Transitional arrangements in relation to amendments introduced by the Compensation Sourcebook (Investments by Large Unincorporated Associations and Certain Large Partnerships) Instrument 2013 Compliance with paragraph (1) may be relied on as tending to establish compliance with CASS 6.7.2R(1)(b).