CASS Sch 2 Notification requirements
Handbook reference |
Matter to be notified |
Contents of notification |
Trigger event |
Time allowed |
Election to be treated as a CASS medium firm or a CASS large firm |
The fact of that election |
The fact of that election |
To be made at least one week before the election is intended to take effect |
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8 | 8 | 8 | [deleted]8 8 |
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8 | 8 | 8 | [deleted]8 8 |
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8 | 8 | 8 | [deleted]8 8 |
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The highest total amount of client money and the highest total value of safe custody assets held by a firm, as more fully described in CASS 1A.2.9 R |
The highest total amount of client money and safe custody assets held by a firm, as more fully described in CASS 1A.2.9 R. |
The need to comply with CASS 1A.2.9 R (1)- (3) |
By the fifteenth business day of January8 unless contrary provision is made in CASS 1A.2.9 R 8 |
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A firm's ‘CASS firm type’ classification |
A firm's ‘CASS firm type’ classification |
The need to comply with CASS 1A.2.9 R (4) |
At the same time the firm makes the notification under CASS 1A.2.9 R (1), (2) or (3)8 8 |
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8 | 8 | 8 | [deleted]8 8 |
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4 | 4 | 4 | 4 | [deleted]4 4 |
4 | 4 | 4 | 4 | [deleted]4 4 |
4 | 4 | 4 | 4 | [deleted]4 4 |
4 | 4 | 4 | 4 | [deleted]4 4 |
4 | 4 | 4 | 4 | [deleted]4 4 |
4 | 4 | 4 | 4 | [deleted]4 4 |
4 | 4 | 4 | 4 | [deleted]4 4 |
4 | 4 | 4 | 4 | [deleted]4 4 |
4 | 4 | 4 | 4 | [deleted]4 4 |
4 | 4 | 4 | 4 | [deleted]4 4 |
Failure of bank, broker or settlement agent2 |
Full details including whether it intends to make good any shortfall that may have arisen in the amounts involved2 |
Immediately2 |
2
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Inability to perform the calculation required by CASS 5.5.84 R2 |
Inability to perform the calculation2 |
Inability to perform the calculation2 |
Immediately2 |
2
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Inability to make good any shortfall identified by CASS 5.5.84 R2 |
Inability to make good any shortfall in client money2 |
Immediately2 |
2
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Inability to comply with the requirements in CASS 5.5.84 R; CASS 5.5.84 R; CASS 5.5.84 R; CASS 5.5.84 R; CASS 5.5.84 R2 |
Inability to comply with the requirements of the rules listed2 |
Inability to comply with the requirements of the rules listed2 |
As soon as reasonably practicable2 |
2
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12 | Inability12 to comply with the requirements in CASS 6.6.2 R to CASS 6.6.4 R (Records, accounts and reconciliations)12 12 |
The fact that the firm has not complied or is unable, in any material respect, to comply with the requirements and the reasons for that |
Non-compliance or inability, in any material respect, to comply with the requirements |
Without delay9 |
12 | Non-compliance or material inability to comply with the requirements in CASS 6.6.2 R (Records, accounts and reconciliations)12 and/or article 89(1)(b) or 89(1)(c) (Safekeeping duties with regard to assets held in custody) of the AIFMD level 2 regulation 12 |
The fact that the firm has not complied or is materially unable to comply with the requirements and the reasons for that |
Non-compliance or material inability to comply with the requirement |
Without delay |
Inability or material failure to take the steps required under CASS 6.6.54 R for the treatment of shortfalls. |
The fact that the firm is unable or has materially failed to comply and the reasons for that |
Inability or material failure to comply with the requirement |
Without delay |
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Inability or material failure to conduct an internal custody record check under CASS 6.6.11 R to CASS 6.6.19 R |
The fact that the firm is unable or has materially failed to comply and the reasons for that |
Inability or material failure to comply with the requirement |
Without delay |
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Inability or material failure to conduct a physical asset reconciliation in compliance with CASS 6.6.22 R to CASS 6.6.30 R |
The fact that the firm is unable or has materially failed to comply and the reasons for that |
Inability or material failure to comply with the requirement |
Without delay |
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Inability or material failure to conduct an external custody record check in compliance with CASS 6.6.34 R to CASS 6.6.37 R |
The fact that the firm is unable or has materially failed to comply and the reasons for that |
Inability or material failure to comply with the requirement |
Without delay |
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12 | The firm's intention to transfer client money under CASS 7.11.42R and/or CASS 7.11.44R |
That intention |
Forming the intention |
Not less than seven days before the transfer of the client money in question |
Firm's intention to adopt the alternative approach for a particular business line |
Firm's intention to adopt the alternative approach for a particular business line |
At least three months prior to adopting the alternative approach for that business line |
At least three months prior to adopting the alternative approach for that business line |
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12CASS 7.15.18R (1)(b) 12 |
Firm's intention to use a non-standard method of internal client money reconciliation |
Firm's intention to use a non-standard method of internal client money reconciliation |
Forming the intention |
Before using a non-standard method of internal client money reconciliation |
Non-compliance or inability, in any material respect, to comply with the requirements in CASS 7.6.13R to CASS 7.6.15R (Reconciliation discrepancies) |
The fact that the firm has not complied or is unable, in any material respect, to comply with the requirements and the reasons for that |
Non-compliance or inability, in any material respect, to comply with the requirements |
Without delay |
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Inability to comply with CASS 7.15.2 R, CASS 7.15.3 R or CASS 7.15.5R (1), due to materially out of date, inaccurate or invalid internal records and accounts |
The fact that the firm is unable to comply and the reasons for that |
Firm's records and accounts are materially out of date, inaccurate or invalid internal so that it is unable to comply |
Without delay |
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Inability to comply with CASS 7.15.29 R after having carried out an internal client money reconciliation |
The fact that the firm is unable to comply and the reasons for that |
Firm's records and accounts are materially out of date, inaccurate or invalid internal so that it is unable to comply |
Without delay |
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Inability or material failure to identify and correct any discrepancies under CASS 7.15.31 R to CASS 7.15.32 R after having carried out an external client money reconciliation |
The fact that the firm is unable to comply and the reasons for that |
Inability or material failure to comply |
Without delay |
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Inability or material failure to conduct an internal client money reconciliation under CASS 7.15.12 R and CASS 7.15.15 R |
The fact that the firm is unable to comply and the reasons for that |
Inability or material failure to comply |
Without delay |
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Inability or material failure to conduct an external client money reconciliation under CASS 7.15.20 R to CASS 7.15.28 R |
The fact that the firm is unable to comply and the reasons for that |
Inability or material failure to comply |
Without delay |
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Amount of client money segregated in client bank accounts materially differing from client money segregation requirements during preceding 12 months |
The fact of the material difference and the reasons for that |
Without delay |
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Material change to sub-pool |
Fact of proposed change, risks and consequences to beneficiaries |
Firm determining that it wishes to make material change to a sub-pool |
Not less than two months before the date on which the firm intends the change to take effect |
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Establishment of a sub-pool of client money to FCA |
Firm wishes to establish a sub-pool of client money |
Firm determining that it wishes to establish a sub-pool of client money |
Not less than two months before the date on which the firm intends to receive or hold client money for that sub-pool |
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Non-compliance, or inability to comply with, with the requirements in CASS 7.19.11 R or CASS 7.19.18 R |
The fact that the firm has not complied with, or is unable to comply with, the requirements of CASS 7.19.11 R or CASS 7.19.18 R (as applicable) |
Non-compliance with the applicable requirement |
Without delay |
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4 | Failure of a third party with which money is held – i.e.: bank, intermediate broker, settlement agent or OTC counterparty or other entity with which it has placed or to which it has passed client money |
Full details |
As soon as the firm becomes aware |
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4 | Failure of a third party with which money is held – i.e.: bank, intermediate broker, settlement agent or OTC counterparty or other entity with which it has placed or to which it has passed client money |
Intentions regarding making good any shortfall that has arisen or may arise, and of the amounts involved |
Failure of third party with which client money is held |
As soon as reasonably practical7 |
If a firm has not complied with, or is unable to comply with, CASS 10.1.3 R |
The fact of that firm's non-compliance or inability to comply with the rule in CASS 10.1.3 R |
Non-compliance or inability to comply with CASS 10.1.3 R |
Immediately (as per CASS 10.1.16 R) |
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The highest total amount of client money held in the previous year or projected to be held in the current year, as more fully described in CASS 11.2.4 R |
The highest total amount of client money held in the previous year or projected to be held in the current year, as more fully described in CASS 11.2.4 R |
The need to comply with CASS 11.2.4 R (1) to CASS 11.2.4 R (3) |
By the fifteenth day of January unless contrary provision is made in CASS 11.2.4 R (1) to CASS 11.2.4 R (4) |
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A firm's CASS debt management firm type classification |
A firm's CASS debt management firm type classification |
The need to comply with CASS 11.2.4 R (4) |
At the same time as the notification in CASS 11.2.4 R (1) to CASS 11.2.4 R (4) |
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Non-compliance with requirements in CASS 11.11.1 R to CASS 11.11.4 R |
Non-compliance with requirements in CASS 11.11.1 R to CASS 11.11.4 R |
The non-compliance |
Without delay |
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Amount of money segregated in client bank accounts is materially different from total aggregate of client money required to be segregated |
The fact that there is a material difference |
Awareness of the difference |
Without delay |
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A CASS large debt management firm's inability or failure to comply with CASS 11.11.23 R, CASS 11.11.28 R, CASS 11.11.13 R or CASS 11.11.25 R |
The inability or failure to comply |
Awareness of the inability or failure |
Without delay |
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A CASS large debt management firm's inability or failure to comply with CASS 11.12.2 R or CASS 11.12.6 R |
The inability or failure to comply |
Awareness of the inability or failure |
Without delay |
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Issue of an individual letter of credit issued by the firm |
Upon issue of an individual letter of credit under an LME bond arrangement |
Immediately |