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

Product Information

CASS 5.5.23 R allows a firm with appointed representatives, field representatives and other agents to

The firm may choose to allocate the function in CASS 13.2.3R to someone who is not an SMF manager. If so: EG 3.8A Information requests and entry of premises under warrant to assist EEA regulators in relation to the Market Abuse Regulation or the auction regulation [deleted] MCOB 15.3 Further provisions about the application of MCOB where agreements are facilitated by a P2P platform FEES 3 Annex 11 Guidance on fees due under FEES 3 Annex 1R, FEES 3 Annex 3R, FEES 3 Annex 8R, FEES 3 Annex 10R, FEES 3.2.7R(p), FEES 3.2.7R(s) and FEES 3.2.7R(ze) ledgers as amounts due from clients, insurance undertakings and other persons, such debts valued on a prudent andCASS obligations are designed to be risk-based, in proportion to the amount of client assets held by your business. SUP TP 8 Financial Services (Banking Reform) Act 2013: Approved persons in small non-directive insurers

Client accounts may not be used to reimburse other creditors in the event of the firm’s insolvency. ( CASS 5.3 and CASS 5.4) MIPRU 5 Insurance distributors and home finance providers using insurance distribution or home finance mediation services

More Resources:

PERG 10 Annex 3 Table summarising regulatory position of pension scheme trustees and service providers SUP 15B Applications and notifications under the benchmarks regulation and powers over Miscellaneous BM persons In addition to these general duties, the CASS rules contain various requirements to notify us of specific issues (for example if a firm is unable to carry out a reconciliation or unable to pay any shortfall into a client bank account).

SUP 10A Annex 6 Form C: Notice of ceasing to perform controlled functions (including senior management functions) [deleted] SUP TP 3 Transitional provisions relating to SUP 10A and SUP 10B: Transition from the FSA to the FCA and PRA You must complete the CASS classification questionnaire every year within 15 working days of 31 December. SUP 10C Annex 4R Form B: Notice to withdraw an application to perform controlled functions (including senior management functions) MAR 7 Disclosure of information on certain trades undertaken outside a regulated market or MTF [deleted]PERG 8.13 Exemptions applying to financial promotions concerning deposits and certain contracts of insurance MIFIDPRU 4 Annex 11R Application under MIFIDPRU 4.5.9R – permission to rebase fixed overhead requirement MIFIDPRU TP 7 Transitional provision for own funds instruments without UK CRR approvals before 1 January 2022

Protecting client assets can be a complex area requiring your business to establish robust procedures and undertake regular oversight and monitoring. Harper James’ financial services solicitors are available to provide advice and support for regulated firms (both large and small) on establishing effective protection for your client assets and complying with your regulatory obligations. What is CASS and what does it aim to do?GEN TP 6 Transitional provisions applying to GEN only - status disclosure for temporary permission firms CONC 2.6 Conduct of business: debt counselling, debt adjusting and providing credit information services COBS 6 Annex 2 Combined initial disclosure document described in COBS 6.3, ICOBS 4.5 and MCOB 4.4A.20G [deleted]