CASS Sch 2 Notification requirements

5CASS 1A.2.5 R

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

CASS 1A.2.8 R (1) - (3)

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CASS 1A.2.8 R (4)

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6CASS 1A.2.8A R

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CASS 1A.2.9 R (1) - (3)

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

CASS 1A.2.9 R (4)

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

CASS 1A.3.2 R

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CASS 5.5.61R14

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

As soon as the firm becomes aware2

Immediately2

CASS 5.5.76R14

Inability to perform the calculation required by CASS 5.5.63R(1)14

Inability to perform the calculation2

Inability to perform the calculation2

Immediately2

CASS 5.5.77R14

Inability to make good any shortfall identified by CASS 5.5.63R(1)14

Inability to make good any shortfall in client money2

Inability to make good any shortfall2

Immediately2

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CASS 6.6.57R (1)1312

Inability12 to comply with the requirements in CASS 6.6.2 R to CASS 6.6.4 R (Records, accounts and reconciliations)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

CASS 6.6.57R (2)1312

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

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

CASS 6.6.57R (3)12

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

12CASS 6.6.57R (4)

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

12CASS 6.6.57R (5)

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

12CASS 6.6.57R (6)

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

CASS 7.11.47 R1312

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

12CASS 7.4.17D RCASS 7.13.57 R12

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

12CASS 7.15.18R (1)(b)

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

CASS 7.6.16R (2)3

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

12CASS 7.15.33R (1)

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

12CASS 7.15.33R (2)

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

12CASS 7.15.33R (3)

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

12CASS 7.15.33R (4)

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

12CASS 7.15.33R (5)

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

CASS 7.15.33R (6)12

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

12CASS 7.19.21 R

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

12CASS 7.19.22 R

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

12CASS 7.19.24 R

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

CASS 7A.3.19R (1)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

Firm becomes aware of the failure of the entity

As soon as the firm becomes aware

CASS 7A.3.19R (2)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

7CASS 10.1.16 R

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)

10CASS 11.2.4 R (1) to CASS 11.2.4 R (3)

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)

10CASS 11.2.4 R (4)

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)

10CASS 11.11.30 R (1)

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

10CASS 11.11.30 R (2)

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

10CASS 11.11.31 R11

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

10CASS 11.12.7 R

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

12CASS 12.2.5 R

LME bond arrangements

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