CASS Sch 1 Record keeping requirements
The aim of the guidance in the following table is to give the reader a quick overall view of the relevant record keeping requirements. |
Handbook reference |
Subject of record |
Contents of record |
When record must be made |
Retention period |
Allocation of the CASS oversight responsibilities in CASS 1A.3.1 R,9 of the CASS operational oversight function, or of the responsibilities in CASS 1A.3.1C R (2),9 as relevant6 9 |
The person to whom the CASS oversight responsibilities have been allocated, subject to the provisions of CASS 1A.3.3 R, to whom the CASS operational oversight function has been allocated in accordance with CASS 1A.3.1A R6, or to whom the responsibilities in CASS 1A.3.1C R (2) have been allocated9 9 |
Upon allocation6 |
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8CASS 1.4.12 R and, where applicable, CASS 1.4.13 R |
For a firm which carries on auction regulation bidding, election (under CASS 1.4.9 R) to comply with CASS in respect of this activity and, where applicable, decision to discontinue use of that opt in |
Record of this election or, where applicable, the decision to discontinue use of the opt in, including the date on which either is to be effective |
Upon making the election or, where applicable, upon taking the decision to discontinue use of the opt in |
5 years from the date on which the opt in ceases to be used |
| 5 | 5 | 5 | [deleted]5 5 |
|
| 5 | 5 | 5 | 5 | [deleted]5 5 |
| 5 | 5 | 5 | 5 | [deleted]5 5 |
| 5 | 5 | 5 | 5 | [deleted]5 5 |
| 5 | 5 | 5 | 5 | [deleted]5 5 |
| 5 | 5 | 5 | 5 | [deleted]5 5 |
| 5 | 5 | 5 | 5 | [deleted]5 5 |
| 5 | 5 | 5 | 5 | [deleted]5 5 |
Record of election of compliance with specified CASS rules5 25 |
Record of compliance with specified CASS rules5 25 |
Not specified2 |
Not specified2 |
2
|
Holding client money as agent2 |
The terms of the agreement2 |
Not specified2 |
Six years2 |
2
|
Adequacy of systems and controls2 |
Written confirmation of adequate systems and controls from its auditor2 |
Not specified2 |
Not specified2 |
2
|
Client money calculation2 |
Whether the firm calculates its client money requirements according to CASS 5.5.84 R or CASS 5.5.84 R2 |
Not specified2 |
Not specified2 |
2
|
Transactions and commitments for client money2 |
Explanation of the firm's transactions and commitments for client money2 |
Not specified2 |
2 | |
Client's title to a contract of insurance2 |
Identity of such documents and/or property and dates received and delivered to client2 |
Not specified2 |
Three years2 |
2
|
A personal investment firm that temporarily holds a client's designated investments which is not in the course of MiFID business |
Client details and any actions taken by the firm |
5 years (from the making of the record) |
||
Client custody assets which the firm has arranged for another to hold or receive |
Full details |
On receipt |
5 years |
|
| 5 | 5 | 5 | 5 | [deleted]5 5 |
3CASS 6.3.1R (4) |
Appropriateness of a firm's selection of a third party 5 |
Grounds upon which a firm satisfies itself as to the appropriateness of the firm's selection of a third party to hold safe custody assets5 belonging to clients 55 |
Date of the selection |
5 years (from the date the firm ceases to use the third party to hold safe custody assets 5belonging to clients) 5 |
Details of clients and safe custody assets 5used for the firm's own account or the account of another client of the firm 5 |
Details of the client on whose instructions the use of the safe custody assets 5 has been effected and the number of safe custody assets 5used belonging to each client 55 |
Maintain up to date records |
5 years (from the date the record was made) |
|
Safe custody assets 5held for each client and the firm's own applicable assets5 55 |
All that is necessary to enable the firm to distinguish safe custody assets 5 held for one client from safe custody assets 5held for any other client, and from the firm's own applicable assets5 555 |
Maintain up to date records |
5 years (from the date the record was made) |
|
Safe custody assets 5held for clients 5 |
Accurate records which 5ensure their5correspondence to the safe custody assets held for clients5 555 |
Maintain up to date records |
5 years (from the date the record was made) |
|
Client agreements that include a firm’s right to use safe custody assets for its own account |
A copy of every executed client agreement that includes a firm’s right to use safe custody assets for its own account |
Maintain up-to-date records |
5 years (from the date the record was made) |
|
| 5 | Record of election to comply with the client money chapter 5 |
Record of election to comply with the client money chapter, including the date from which the election is to be effective 5 |
Date of the election |
5 years (from the date the firm ceases to use the election) |
Record of election in relation to CASS 7.1.15C R |
Record of election in relation to CASS 7.1.15C R |
Date of election |
Not specified |
|
Appropriateness of a firm's selection of a third party 5 |
Grounds upon which a firm satisfies itself as to the appropriateness of the firm's selection of a third party to hold client money 5 |
Date of the selection |
5 years (from the firm ceases to use the third party to hold client money) |
|
Client money held for each client and the firm's own money |
All that is necessary to enable the firm to distinguish client money held for one client from client money held for any other client, and from the firm's own money |
Maintain up to date records |
Five years (from the date the record was made) |
|
Client money held for each client |
Accurate records to ensure the correspondence between the records and accounts of the entitlement of each client for whom the firm holds client money with the records and accounts of the client money the firm holds in client bank accounts and client transaction accounts |
Maintain up to date records |
Five years (from the date the record was made) |
|
Internal reconciliation of client money balances |
Explanation of method of internal reconciliation of client money balances used by the firm, and if different from the standard method of internal client money reconciliation, an explanation as to how the method used affords equivalent degree of protection to clients, and how it enables the firm to comply with the client money distribution rules 5 |
Date the firm starts using the method |
5 years (from the date the firm ceases to use the method) |
|
| 5 | Each client's entitlement to client money shortfall at the failed bank |
Maintain up to date records |
Until client is repaid |
|
Each client's entitlement to client money shortfall at the failed bank |
Maintain up to date records |
Until client is repaid |
||
| 5 | Each client's entitlement to client money shortfall at the failed bank |
Maintain up to date records |
Until client is repaid |
|
| 5 | Each client's entitlement to client money shortfall at the failed intermediate broker, settlement agent or OTC counterparty |
Maintain up to date records |
Until client is repaid |
|
Adequate records and internal controls in respect of the firm's use of mandates9 (see CASS 8.3.2R (1)9 to CASS 8.3.2R (5)9 ) 999 |
Up to date list of firm's mandates9 and any conditions regarding the use of mandates9, all transactions entered into, details of procedures and internal controls9 for giving and receiving of instructions under mandates9, and important client documents held by the firm 9999 |
Maintain current full details |
Not specified7 |
|
From the date on which a firm becomes subject to CASS 10.1.3 R |
None is specified |
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Allocation of CASS oversight function in CASS 11.3.1 R or CASS 11.3.2 R, or CASS operational oversight function in CASS 11.3.4 R |
The person to whom (as applicable) the CASS oversight responsibilities have been allocated, or to whom the CASS operational oversight function has been allocated |
Upon allocation |
5 years (from the date the record was made) |
|
Appropriateness of a CASS large debt management firm's selection of an approved bank |
Grounds upon which a CASS large debt management firm satisfies itself as to the appropriateness of the firm's selection of an approved bank at which to hold client money |
Date of the selection |
5 years (from the date the firm ceases to use the approved bank to hold client money) |
|
Client bank account acknowledgement letters sent in accordance with CASS 11.8.2 R |
Each countersigned client bank account acknowledgement letters received |
On receipt of each letter |
5 years (following closure of the last client bank account to which the letter relates) |
|
Demonstration that a CASS debt management firm has complied with CASS 11.8.2 R to CASS 11.8.7 R |
Evidence of such compliance |
On compliance with the relevant provision |
None specified |
|
Money received from clients in the form of cash, cheques or other payable orders |
Details of money received |
On receipt |
None specified |
|
Unidentified client money under CASS 11.9.8 R (2) |
Details of unidentified client money held |
Being unable to identify money as client money or its own money, and deciding it is reasonably prudent to so record |
Until it performs the necessary steps to identify the money under CASS 11.9.8 R (1) |
|
Client money held for each client and the CASS debt management firm's own money |
All that is necessary to enable the CASS debt management firm to distinguish client money held for one client from client money held for any other client, and from the firm's own money |
Maintain up-to-date records |
None is specified |
|
Client money held for each client |
Accurate records to ensure the correspondence between the records and accounts of the entitlement of each client for whom the CASS debt management firm holds client money with the records and accounts of the client money the firm holds in client bank accounts |
Maintain up-to-date records |
None is specified |
|
Payments made to, for or on behalf of clients by a CASS debt management firm and written and oral contact with clients and creditors |
Details of payments made and of the written or oral contact |
Maintain up-to-date records |
None is specified |
|
The documents to which CASS 11.12.3 R and CASS 11.12.4 R refer. |
From the date on which a CASS debt management firm becomes subject to CASS 11.12.3 R |
None is specified |
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A CASS large debt management firm's record of each client's shortfall in the event of a secondary pooling event |
Details of the shortfall |
On the secondary pooling event occurring |
None is specified |