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CASS Sch 1 Record keeping requirements

CASS Sch 1.1G

1

The aim of the guidance in the following table is to give the reader a quick overall view of the relevant record keeping requirements.

CASS Sch 1.2G

It is not a complete statement of those requirements and should not be relied on as if it were.

CASS Sch 1.3G
222222

Handbook reference

Subject of record

Contents of record

When record must be made

Retention period

6CASS 1A.3.3 R

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

5 years (from the date the record was made)68

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

CASS 5.1.1 R (4)2

Record of election of compliance with specified CASS rules5

25

Record of compliance with specified CASS rules5

25

Not specified2

Not specified2

CASS 5.2.3 R (2)2

Holding client money as agent2

The terms of the agreement2

Not specified2

Six years2

CASS 5.4.4 R (2)2

Adequacy of systems and controls2

Written confirmation of adequate systems and controls from its auditor2

Not specified2

Not specified2

CASS 5.5.84 R2

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

CASS 5.5.84 R2

Transactions and commitments for client money2

Explanation of the firm's transactions and commitments for client money2

Not specified2

Three years23

CASS 5.8.3 R (1)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

5CASS 6.1.16CR (3)

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)

5CASS 6.1.16K R

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

3CASS 6.4.3 R

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)

3CASS 6.5.1 R

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)

3CASS 6.5.2 R

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)

6CASS 6.5.2A R

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)

3CASS 7.1.3R (2)54

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)

5CASS 7.1.15C R

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

3CASS 7.4.10 R

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)

3CASS 7.6.1 R

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)

3CASS 7.6.2 R

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)

3CASS 7.6.7 R

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)

CASS 7A.3.8R (3)5

5

Client money shortfall

Each client's entitlement to client money shortfall at the failed bank

Maintain up to date records

Until client is repaid

35CASS 7A.3.10R (3)5

Client money shortfall

Each client's entitlement to client money shortfall at the failed bank

Maintain up to date records

Until client is repaid

CASS 7A.3.11R (3)5

5

Client money shortfall

Each client's entitlement to client money shortfall at the failed bank

Maintain up to date records

Until client is repaid

CASS 7A.3.17R (3)5

5

Client money shortfall

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

39CASS 8.3.1 R9

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

7CASS 10.1.3 R

A firm's CASS resolution pack

The documents to which CASS 10.2 and CASS 10.3 refer

From the date on which a firm becomes subject to CASS 10.1.3 R

None is specified

10CASS 11.3.6 R

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)

10CASS 11.7.6 R

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)

10CASS 11.8.8 R

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)

10CASS 11.8.9 R

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

10CASS 11.9.5 R

Money received from clients in the form of cash, cheques or other payable orders

Details of money received

On receipt

None specified

10CASS 11.9.8 R (2)

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)

10CASS 11.11.1 R

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

10CASS 11.11.3 R

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

10CASS 11.11.4 R

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

10CASS 11.12.4 R

A CASS debt management firm's CASS 11 resolution pack

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

10CASS 11.13.12 R (3)

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