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CASS 1A.2 CASS firm classification

CASS 1A.2.1G

The application of certain rules in this chapter depends upon the ‘CASS firm type’ within which a firm falls. The ‘CASS firm types’ are defined in accordance with CASS 1A.2.7 R. The ‘CASS firm type’ within which a firm falls is also used to determine whether it is required to have the CASS operational oversight function described in CASS 1A.3.1A R and1 whether 4the reporting obligations in SUP 16.14 (Client money and asset return) apply to it4.

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CASS 1A.2.2R
  1. (1)

    A firm must once every year, and by the time it is required to make a notification in accordance with4 CASS 1A.2.9R (4), determine whether it is a CASS large firm, CASS medium firm or a CASS small firm according to the amount of client money or safe custody assets which it holds, using the limits set out in the table in CASS 1A.2.7 R.

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  2. (2)

    For the purpose of determining its ‘CASS firm type’ in accordance with CASS 1A.2.7 R, a firm must:

    1. (a)

      if it currently holds client money or safe custody assets, calculate the higher of the highest total amount of client money and the highest total value of safe custody assets held during the previous calendar year ending on 31 December and use that figure to determine its ‘CASS firm type’;

    2. (b)

      if it did not hold client money or safe custody assets in the previous calendar year but projects that it will do so in the current calendar year, calculate the higher of the highest total amount of client money and the highest total value of safe custody assets that it projects that it will hold during that year and use that figure to determine its ‘CASS firm type’; but

    3. (c)

      in either case, exclude from its calculation any client money held in accordance with CASS 5 (Client money: insurance mediation activity).

CASS 1A.2.3R

For the purpose of calculating the value of the total amounts of client money and safe custody assets that it holds on any given day during a calendar year a firm must:

  1. (1)

    in complying with CASS 1A.2.2R (2)(a), base its calculation upon internal reconciliations performed during the previous year;

  2. (2)

    in relation to client money or safe custody assets denominated in a currency other than sterling, translate the value of that money or that safe custody assets into sterling at the previous day’s closing spot exchange rate; and

  3. (3)

    in relation to safe custody assets only, calculate their total value using the previous day’s closing mark to market valuation, or if in relation to a particular safe custody asset none is available, the most recent available valuation.

CASS 1A.2.4G

One of the consequences of CASS 1A.2.2 R is that a firm that determines itself to be a CASS small firm or a CASS medium firm will, at least if it exceeds during the course of a calendar year either of the limits in CASS 1A.2.7 R that applies to it, become in the next calendar year:

  1. (1)

    in the case of a CASS small firm, a CASS medium firm or a CASS large firm; and

  2. (2)

    in the case of a CASS medium firm, a CASS large firm.

CASS 1A.2.5R
  1. (1)

    Notwithstanding CASS 1A.2.2 R, provided that the conditions in (2) are satisfied a firm may elect to be treated:

    1. (a)

      as a CASS medium firm, in the case of a firm that is classed by the application of the limits in CASS 1A.2.7 R as a CASS small firm; and

    2. (b)

      as a CASS large firm, in the case of a firm that is classed by the application of the limits in CASS 1A.2.7 R as a CASS medium firm.

  2. (2)

    The conditions to which (1) refers are that in either case:

    1. (a)

      the election is notified4 to the FCAin writing4;

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    2. (b)

      the notification in accordance with (a) is made4 at least one week before the election is intended to take effect; and

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    3. (c)

      the FCA has not objected.

CASS 1A.2.6G

CASS 1A.2.5 R provides a firm with the ability to opt in to a higher category of ‘CASS firm type’. This may be useful for a firm whose holding of client money and safe custody assets is near the upper categorisation limit for a CASS small firm or a CASS medium firm.

CASS 1A.2.7R

CASS firm types

CASS firm type

Highest total amount of client money held during the firm’s last calendar year or as the case may be that it projects that it will hold during the current calendar year

Highest total value of safe custody assets held by the firm during the firm's last calendar year or as the case may be that it projects that it will hold during the current calendar year

CASS large firm

more than £1 billion

more than £100 billion

CASS medium firm

an amount equal to or greater than £1 million and less than or equal to £1 billion

an amount equal to or greater than £10 million and less than or equal to £100 billion

CASS small firm

less than £1 million

less than £10 million

CASS 1A.2.8R

[deleted]4

CASS 1A.2.8AR

[deleted]4

CASS 1A.2.9R

Once every calendar year a firm must notify to the FCA in writing the information specified in (1), (2) or (3) as applicable, and the information specified in (4), in each case no later than the day specified in (1) to (4):4

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  1. (1)

    if it held client money or safe custody assets in the previous calendar year, the highest total amount of client money and the highest total value of safe custody assets held during the previous calendar year, notification of which must be made no later than the fifteenth business day of January; or4

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  2. (2)

    if it did not hold client money or safe custody assets in the previous calendar year but at any point up to the fifteenth business day of January the firm projects that it will do so in the current calendar year, the highest total amount of client money and the highest total value of safe custody assets that the firm projects that it will hold during the current calendar year, notification of which must be made no later than the fifteenth business day of January4; or

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  3. (3)

    in any other case, the highest total amount of client money and the highest total value of safe custody assets that the firm projects that it will hold during the remainder of the current calendar year, notification of which must be made no later than the business day before the firm begins to hold client money or safe custody assets4; and

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  4. (4)

    in every case, of its ‘CASS firm type’ classification, notification of which must be made at the same time the firm makes the notification under (1), (2) or (3)4.

CASS 1A.2.10R

For the purpose of the annual notification to which CASS 1A.2.9 Rrefers4, a firm must apply the calculation rule in CASS 1A.2.3 R.

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CASS 1A.2.11G

For the purpose of CASS 1A.2.9R (1), the FCA will treat that obligation as satisfied if a firm submitted4 a CMAR for each period within the previous calendar year 4 in compliance with SUP 16.14.3 R.3

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CASS 1A.2.12R

4A firm's 'CASS firm type' and any change to it takes effect:

  1. (1)

    if the firm notifies the FCA in accordance with CASS 1A.2.9 R (1) or CASS 1A.2.9 R (2), on 1 February following the notification; or

  2. (2)

    if the firm notifies the FCA in accordance with CASS 1A.2.9 R (3), on the day it begins to hold client money or safe custody assets; or

  3. (3)

    if the firm makes an election under CASS 1A.2.5 R (1), and provided the conditions in CASS 1A.2.5 R (2) are satisfied, on the day the notification made under CASS 1A.2.5 R (2)(a) states that the election is intended to take effect.

CASS 1A.2.13G

4Any written notification made to the FCA under this chapter should be marked for the attention of: "Client Assets Firm Classification".