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 |
A personal investment firm that temporarily holds a client's designated investments |
Client details and any actions taken by the firm |
3 years (from the making of the record) |
||
Safe custody: arrangements for clients ordinarily outside the United Kingdom |
The steps taken and result under CASS 2.3.6 R (1)(c) |
On determination that client does not wish to execute agreement |
3 years |
|
Client custody assets held or received by or on behalf of a client or which the firm has arranged for another to hold or receive |
Full details |
On receipt |
3 years |
|
Safe custody investments used for stock lending activities |
The identity of safe custody investments available to be lent, and those which have been lent |
On receipt |
3 years |
|
Client money |
Sufficient records to show and explain firm's transactions and commitments |
Maintain current full details |
3 years (after records made) |
|
Client money shortfall |
Each client's entitlement to client money shortfall at the failed bank |
Maintain up to date records |
Until client repaid |
|
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 repaid |
|
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 repaid3 |
|
Record of election of compliance with CASS 5.8 to CASS 5.8 provisions2 |
Record of compliance with CASS 5.8 to CASS 5.8 provisions on client money2 |
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
|
Record of election to comply with the MiFID custody chapter |
Record of election to comply with the MiFID custody chapter, including the date from which the election is to be effective |
Date of the election |
5 years (from the date the firm ceases to use the election) |
|
3 CASS 6.3.1R (4) |
Appropriateness of a MiFIDinvestment firm's selection of a third party |
Grounds upon which a MiFIDinvestment firm satisfies itself as to the appropriateness of the firm's selection of a third party to hold financial instruments belonging to clients |
Date of the selection |
5 years (from the date the firm ceases to use the third party to hold financial instruments belonging to clients) |
Details of clients and financial instruments used for the firm's own account or the account of another client of the firm |
Details of the client on whose instructions the use of the financial instruments has been effected and the number of financial instruments used belonging to each client |
Maintain up to date records |
5 years (from the date the record was made) |
|
Financial instruments held for each client and the firm's own financial instruments |
All that is necessary to enable the firm to distinguish financial instruments held for one client from financial instruments held for any other client, and from the firm's own financial instruments |
Maintain up to date records |
5 years (from the date the record was made) |
|
Financial instruments held for clients |
Accurate records toensure thecorrespondence between the financial instruments held for each client and the financial instruments held by the firm and third parties |
Maintain up to date records |
5 years (from the date the record was made) |
|
Record of election to comply with the MiFID client money chapter |
Record of election to comply with the MiFID client money chapter, including the date from which the election is to be effective |
Date of the election |
5 years (from the date the firm ceases to use the election) |
|
Appropriateness of a MiFIDinvestment firm's selection of a third party |
Grounds upon which a MiFIDinvestment firm satisfies itself as to the appropriateness of the firm's selection of a third party to hold client money |
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(MiFID business) distribution rules |
Date the firm starts using the method |
5 years (from the date the firm ceases to use the method) |
|
Each client's entitlement to client moneyshortfall at the failed bank |
Maintain up to date records |
Until client is repaid |
||
Each client's entitlement to client moneyshortfall at the failed bank |
Maintain up to date records |
Until client is repaid |
||
Each client's entitlement to client moneyshortfall at the failed bank |
Maintain up to date records |
Until client is repaid |
||
Each client's entitlement to client moneyshortfall 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 mandates (see CASS 8.1.5R (1) to CASS 8.1.5R (4) ) |
Up to date list of firm's authorities and any conditions regarding the use of authorities, all transactions entered into, details of procedures and authorities for giving and receiving of instructions under authorities, and important client documents held by the firm |
Maintain current full details |
Not specified |