Client Money & CMAR: Important Changes

In Regulatory Roundup 28 we reminded CASS large and CASS medium firms that the requirement to complete a CMAR (Client Money and Assets Return) was to begin in June.

In the recently published Policy Statement PS11/6 (‘The Client Money and Asset Return (CMAR): Operational Implementation’) the FSA has announced a delay in the reporting starting date in response to feedback on the tight timetable. The CMAR reporting requirement will now be implemented from 1 October; the 15 day submission timeframe remains unchanged.

PS11/6 also clarifies that the person with CF10a status (see separate article on this function in this Regulatory Roundup) is to be the person completing and submitting the CMAR (and so that individual will also need to be a GABRIEL user).

The rule changes, as well as guidance on the completion of the CMAR, can be found in Appendix 1 of the Policy Statement.

The above applies only to CASS large and CASS medium firms. The CMAR reporting arrangements for CASS small firms will be postponed ‘until further notice’ to allow the FSA to implement the CMAR successfully for the medium and larger firms – a consultation for CASS small firms is proposed for later this year. Note that CASS small firms will be subject to a ‘one-off’ notification in July and the FSA will be contacting such firms in early July (see chapter 4 of Handbook Notice 109 for further information).

The definition of CASS large, medium and small firms can be found in CASS 1A.2.7; a CASS small firm will have held less than £1m in client money and/or £10m in safe custody assets.