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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

11CASS 6.1.6BR (3)

Written agreement regarding any arrangement relating to the transfer of full ownership of a client's safe custody asset to the firm for the purposes set out in CASS 6.1.6R (1) and CASS 6.1.6AR (1)

The agreement

When agreement made

Five years from date agreement terminated

11CASS 6.1.8AR (2)

Client’s communication to firm of wish to terminate TTCA

Client’s communication of wish to terminate TTCA

When communication made

Five years (from date of communication)

11CASS 6.1.8AR (4)

Firm's response to client's wish to terminate TTCA

Firm's response to client's wish to terminate TTCA

When notification given

Five years (from date of communication)

11CASS 6.1.12R (4)

Firm's segregation of money as client money under this rule

Description of safe custody asset in question, identity of relevant client, amount of money segregated

Maintain up to date

Not specified (see default provision CASS 6.5.3 R)

11CASS 6.1.12E R

Client's agreement to firm's use of exemption in CASS 6.1.12 R

Client's written agreement

At the time of client's agreement

During the time the firm makes use or intends to make use of the exemption in CASS 6.1.12 R in respect of that client's safe custody assets

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

11CASS 6.2.15 R

Safe custody assets divested by the firm under CASS 6.2.10 R

Details of asset divested, relevant documentation and the firm's attempts to contact the client concerned

When asset divested

Indefinite

CASS 6.3.2AR (1)11

11

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

11CASS 6.3.2AR (2)

A firm's periodic review into the selection and appointment of a third party under CASS 6.3.1 R

Date of review, actions taken by the firm in reviewing the selection and appointment of a third party under CASS 6.3.1 R, and grounds upon which the firm continues to be satisfied of appropriateness of its selection of that third party to hold safe custody assets belonging to clients

On the date of the review

Five years (from the date the firm ceases to use the third party to hold safe custody assets belonging to clients)

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)

CASS 6.6.2 R11

11

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)

CASS 6.6.3 R11

11

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)

11CASS 6.5.3 R

Default record keeping provision for CASS 6

Refer to the rule concerned

Refer to the rule concerned

Five years from the later of:

(1) the date it was created; and

(2) if it has been modified since the date in (1), the date it was most recently modified

11CASS 6.6.4 R

Client specific safe custody asset record

Client specific safe custody asset record

Maintain up to date

Five years (from the date the record was made)

11CASS 6.6.8 R

Internal custody record checks, physical asset reconciliations and external custody reconciliations carried out by the firm.

Date and actions the firm took when carrying out the relevant process; a list of the discrepancies the firm identified and the actions the firm took to resolve those discrepancies

Immediate

Not specified (see default provision CASS 6.6.7 R

11CASS 6.6.16 R

Aggregate safe custody asset record

All the safe custody assets the firm holds for its clients, including those deposited with third parties under CASS 6.3 and any physical safe custody assets

Maintain up to date if the firm wishes to use the internal custody reconciliation method

Not specified (see default provision CASS 6.6.7 R

11CASS 6.6.30 R

Rolling stock method for physical asset reconciliations

Firm's reasons for concluding that this method is adequately designed to mitigate risk of records being manipulated or falsified

Before using this method

Five years (from the date the firm ceases to use this method)

11CASS 6.6.45 R

Frequency of the firm's internal custody record checks, physical asset reconciliations and external custody reconciliations

Sufficient to show and explain decision taken under CASS 6.6.44 R when determining frequency

Immediate

(1) Subject to (2), indefinitely.

(2) For any decision which is superseded by a subsequent decision, five years from the subsequent decision (with (1) applying to the subsequent decision).

11CASS 6.6.46R (2)

Review of frequency if the firm's internal custody record checks, physical asset reconciliations and external custody reconciliations

Date of each review and the actions the firm took in reviewing the frequency at which it conducts the relevant process

Immediate

Not specified (see default provision CASS 6.6.7 R

11CASS 6.6.54R (2)(a)

Actions taken by the firm to resolve shortfall under this rule

Actions taken, description of shortfall, identity of affected client(s), applicable assets appropriated to cover the shortfall. Update when discrepancy resolved.

Maintain up to date

Not specified (see default provision CASS 6.6.7 R

11CASS 6.6.54R (2)(b)

Actions taken by the firm to resolve shortfall under this rule

Actions taken, description of shortfall, identity of affected client(s), amount of money appropriated to cover the shortfall. Update when discrepancy resolved.

Maintain up to date

Not specified (see default provision CASS 6.6.7 R

CASS 7.11.3R (3)11

511

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)

CASS 7.10.31 R11

11

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 (see default provision CASS 7.6.4 R)11

CASS 7.10.35 R11

11

Trustee firm's election to comply, or to cease to comply, with specific CASS 7 provisions

Relevant provisions, date of election and of any decision to cease to comply

When election made or decision taken to cease to comply

5 years after ceasing to use the election

CASS 7.10.38 R11

11

Trustee firm's election to comply, or to cease to comply, with specific CASS 7 provisions

Relevant provisions, date of election and of any decision to cease to comply

When election made or decision taken to cease to comply

5 years after ceasing to use the election

11CASS 7.2.8AE R12

Client's agreement to firm's use of exemption in CASS 7.2.8 R

Client's written agreement

At the time of client's agreement

During the time the firm makes use or intends to make use of the exemption in CASS 7.2.8 R in respect of that client's monies

CASS 7.11.55 R11

11

Client money paid to charity by the firm under CASS 7.2.19 R

Details of balances released, relevant documentation and the firm's attempts to contact the client concerned

When balance released

Indefinite

CASS 7.11.57R (4)11

11

Client money paid to charity by the firm underCASS 7.2.25 R

Indefinite

When balance released

Not specified (see default provision CASS 7.6.4 R)

CASS 7.13.25R (1)11

11

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)

11CASS 7.4.17B R

Firm's adoption of the alternative approach

Reasons for concluding that the normal approach would lead to greater risk to client money, adopting the alternative approach would not result in undue risk to client money, the alternative approach is appropriate for use by the particular business line, and the firm has adequate systems and controls

Before adopting alternative approach

Five years after it ceases to use the alternative approach in connection with that business line

11CASS 7.4.19A R to CASS 7.4.19C R12

Alternative approach alternative approach mandatory prudent segregation record

Details of money segregated under CASS 7.4.18B R required by these rules

Maintain up to date

Five years (after the firm ceases to retain money as client money under CASS 7.4.18B R)

CASS 7.15.2 R11

11

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)

CASS 7.15.3 R11

11

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)

11CASS 7.6.4 R

Default record keeping provision for CASS 7

Refer to the rule concerned

Refer to the rule concerned

Five years from the later of:

(1) the date it was created; and

(2) if it has been modified since the date in (1), the date it was most recently modified

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)

11CASS 7.8.9R (1)

Acknowledgment letters

Countersigned acknowledgment letter

From date of receipt

5 years from closure of last account to which the acknowledgment letter relates

11CASS 7.8.9R (2)

Acknowledgment letters

Copy of acknowledgment letter sent to authorised central counterparty under CASS 7.8.3R (1)

From date firm sends the letter

5 years from closure of last account to which the acknowledgment letter relates

11CASS 7.8.10 R

Acknowledgment letters

Any other documentation or evidence the firm believes necessary to demonstrate compliance with CASS 7.8

None specified

None specified (see default provision CASS 7.6.4 R)

13CASS 7.10.7ER

The election made under CASS 7.10.7AR

The election including the date from which the election is to be effective and, if the firm cancels the election, the date from which the election is to cease to be effective

At the time of the election and, if the firm cancels the election, at the time it is cancelled

Five years after ceasing to use the election

11CASS 7.11.9R (2)

Client's communication to firm of wish to terminate TTCA

Client's communication of wish to terminate TTCA

When communication made

Five years (from date of communication)

11CASS 7.11.9R (4)

Firm's response to client's wish to terminate TTCA

Firm's response to client's wish to terminate TTCA

When notification given

Five years (from date of notification)

11CASS 7.11.20 R

Client's agreement to firm's use of the delivery versus payment exemption under CASS 7.11.14 R

Written evidence of client's agreement

Immediate

Until the firm ceases to use this exemption

11CASS 7.11.24 R

Client's agreement to firm's use of the delivery versus payment exemption under CASS 7.11.21 R

Written evidence of client's agreement

Immediate

Until the firm ceases to use this exemption

11CASS 7.13.25R (2)

Firm's periodic review into selection and appointment of third party under CASS 7.13.8 R.

Date of each review, actions the firm took in reviewing the selection and appoint of a third party under CASS 7.13.8 R, and the grounds upon which the firm continues to be satisfied of appropriateness of its selection of that third party to hold client money

Date of review

Five years (from date of review)

11CASS 7.13.25R (3)

Firm's periodic review under CASS 7.13.22 R.

Fact of review, its considerations and conclusions

Date of review

Five years (from date of review)

11CASS 7.13.36 R

Unallocated client money

Fact that the balance treated as unallocated client money

When firm is unable to immediately identify money as client money or its own money and it treats the balance as client money

Pending firm's allocation of the client money concerned to an individual client

11CASS 7.13.50 R; CASS 7.13.51 R

Prudent segregation record

Details of money segregated under CASS 7.13.41 R required by these rules

Maintain up to date

Five years (after the firm ceases to retain money as client money under CASS 7.13.41 R)

11CASS 7.13.66 R; CASS 7.13.67 R

Alternative approach mandatory prudent segregation record

Details of money segregated under CASS 7.13.65 R required by these rules

Maintain up to date

Five years (after the firm ceases to retain money as client money under CASS 7.13.65 R)

11CASS 7.13.74 R; CASS 7.13.75 R

Clearing arrangement mandatory prudent segregation record

Details of money segregated under CASS 7.13.73R (3)(a) required by these rules

Maintain up to date

Five years (after the firm ceases to retain money as client money under CASS 7.13.73R (3)(a)

11CASS 7.15.5R (1)

Total amount of client money the firm should be holding for each client

Total amount of client money the firm should be holding for each client

Maintain up to date

Not specified (see default provision CASS 7.15.5R (3))

11CASS 7.15.5R (2)

Transactions and commitments for client money

Sufficient to show and explain transactions and commitments

Maintain up to date

Not specified (see default provision CASS 7.15.5R (3))

11CASS 7.15.7 R

Internal client money reconciliations and external client money reconciliations conducted carried out by the firm

Date, actions the firm took in carrying out the relevant process, and the outcome of its calculation of its client money requirement and client money resource Fact of each reconciliation and review of the firm's arrangements for complying with CASS 7.15.5 R to CASS 7.15.7 R12

Immediate

Not specified (see default provision CASS 7.15.5R (3))

11CASS 7.15.9 R

Receipts of client money

Appropriate to account for all receipts of client money in the form of cash, cheque or other payable order not yet deposited in a client bank account

Maintain up to date

Not specified (see default provision CASS 7.15.5R (3))

11CASS 7.15.24 R

Frequency of the firm's external client money reconciliations

Sufficient to show and explain decision taken under CASS 7.15.23 R12 when determining frequency

Immediate

(1) Subject to (2), indefinitely.

(2) For any decision which is superseded by a subsequent decision, five years from the subsequent decision (with (1) applying to the subsequent decision).

11CASS 7.15.26R (2)

Review of frequency of the firm's external client money reconciliations

Date of each review and the actions the firm took in reviewing the frequency at which it carries out the external client money reconciliations

Not specified

Not specified (see default provision CASS 7.15.5R (3))

11CASS 7.19.6 R

For each sub-pool established by the firm

All the client beneficiaries of that sub-pool

From the date on which the sub-pool is created

Five years following the date on which client money was last held by the firm in relation to the sub-pool to which the record applied

11CASS 7.19.7 R

For each sub-pool established by the firm

(a) The name of the sub-pool

(b) The identity of the net margined omnibus account to which the sub-pool relates;

(c) Each client bank account and each client transaction account maintained for the sub-pool;

(d) the applicable sub-pool disclosure document for the sub-pool.

Prior to the date on which the firm intends to receive or hold client money for that sub-pool

Five years following the date on which client money was last held by the firm in relation to the sub-pool to which the record applied

11CASS 7.19.8 R

For each sub-pool established by the firm

A list of all the sub-pools the firm has created.

From the date on which the sub-pool is created

Five years following the date on which client money was last held by the firm in relation to the sub-pool to which the record applied

11CASS 7.19.9 R

For each sub-pool established by the firm

A sub-pool disclosure document

At the time of establishing the relevant sub-pool

Five years following the date on which client money was last held by the firm in relation to the sub-pool to which the sub-pool disclosure document applied

11CASS 7.19.13R (2)

For each sub-pool established by the firm

The name of each client bank account and each client transaction account maintained for the sub-pool, including a unique identifying reference

From the date on which the client bank account and client transaction account is maintained for the sub-pool

5 years following the date on which client money was last held by the firm in relation to the sub-pool to which the record applied

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 8.3.2 R to CASS 8.3.2C R11 )

99911

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, and, in relation to non-written mandates, the further details required by CASS 8.3.2C R11

9999

Maintain current full details

One year after the firm ceases to have the mandate or, if the mandate was held in the course of or in connection with the firm's MiFID business, five years after the same date11

11

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