Client Money: Loan-Based Crowdfunding

Of Relevance to: Firms advising on P2P agreements; all firms undertaking ‘advising on investments Client Money: Loan-Based Crowdfunding The proposed changes to CASS to allow firms to hold money in relation to both P2P agreements (CASS protection) and business to business agreements (falls outside of CASS protection) without breaching CASS [...]

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CASS changes

A reminder that the second phase of changes to the CASS regime came into being on 1 December – see Regulatory Roundup 56. Policy Statement PS14/9 (‘Review of the client assets regime for investment business’) published in June last year included all the changes to CASS – and to other [...]

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CASS Proposals

Following the proposed changes to CASS 1A (classification and oversight) and CASS 8 (mandates), as mentioned in Regulatory Roundup 43, and the introduction of the CASS resolution pack concept in (new) CASS 10 – see Regulatory Roundup 39 – further changes to the CASS regime are proposed in CP12/22 “Client [...]

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CASS Update

The FSA is consulting (CP12/15) on changes in two areas of CASS: firm classification and oversight (CASS 1A) and mandates (CASS 8). The changes to CASS 1A will include clarification on the CASS firm type effective date. Identified technical issues will result in some minor changes to the CMAR. The [...]

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CASS Resolution Pack

Last August the FSA published a consultation paper (CP11/16) on the proposal for firms that hold client money and/or client assets to produce a CASS resolution pack (CRP) – see Regulatory Roundup 34. The purpose of such a pack is to ensure that a firm maintains information that would, in [...]

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CASS Consultation Paper

The FSA has released Consultation paper CP10/9 – “Enhancing the Client Assets Sourcebook”. Proposals include greater transparency requirements by UK authorised prime brokers (‘PBs’) in respect of re-hypothecation provisions by way of a summary annex (the CP refers to “… sophisticated clients’ lack of understanding …”). Additionally PBs will have [...]

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