Home FCA Handbook CASS CASS Sch 1 CASS Sch 1 Record keeping requirements
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CASS Sch 1 Record keeping requirements

01/12/2004G

 

The aim of the guidance in the following table is to give the reader a quick overall view of the relevant record keeping requirements.
01/12/2004G
It is not a complete statement of those requirements and should not be relied on as if it were.
07/05/2026G
Handbook referenceSubject of recordContents of recordWhen record must be madeRetention period
CASS 1A.3.3 RAllocation of the CASS oversight responsibilities in CASS 1A.3.1 R, of the CASS operational oversight function, or of the responsibilities in CASS 1A.3.1C R (2), as relevantThe 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 R, or to whom the responsibilities in CASS 1A.3.1C R (2) have been allocatedUpon allocation5 years (from the date the record was made)
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CASS 5.1.1 R (4)Record of election of compliance with specified CASS rulesRecord of compliance with specified CASS rulesNot specifiedNot specified
CASS 5.2.3 R (2)Holding client money as agentThe terms of the agreementNot specifiedSix years
CASS 5.4.4 R (2)Adequacy of systems and controlsWritten confirmation of adequate systems and controls from its auditorNot specifiedNot specified
CASS 5.5.84 RClient money calculationWhether the firm calculates its client money requirements according to CASS 5.5.84 R or CASS 5.5.84 RNot specifiedNot specified
CASS 5.5.84 RTransactions and commitments for client moneyExplanation of the firm's transactions and commitments for client moneyNot specifiedThree years
CASS 5.8.3 R (1)Client's title to a contract of insuranceIdentity of such documents and/or property and dates received and delivered to clientNot specifiedThree years
CASS 6.1.6BR (3)Written agreement regarding any arrangement relating to a TTCAThe agreementWhen agreement madeFrom the date the agreement is entered into and until five years after the agreement is terminated
CASS 6.1.8AR(1) and (2)Client’s communication to firm of wish to terminate TTCAClient’s communication of wish to terminate TTCAWhen communication madeFive years (from date of communication)
CASS 6.1.8AR (4)Firm's response to client's wish to terminate TTCAFirm's response to client's wish to terminate TTCAWhen notification givenFive years (from date of communication)
CASS 6.1.12R(5)Firm's segregation of money as client money under this ruleDescription of safe custody asset in question, identity of relevant client, amount of money segregatedMaintain up to dateNot specified (see default provision CASS 6.6.7R)
CASS 6.1.12E RClient's agreement to firm's use of exemption in CASS 6.1.12 RClient's written agreementAt the time of client's agreementDuring 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
CASS 6.1.16CR (3)A personal investment firm that temporarily holds a client's designated investments which is not in the course of MiFID businessClient details and any actions taken by the firm 5 years (from the making of the record)
CASS 6.1.16K RClient custody assets which the firm has arranged for another to hold or receiveFull detailsOn receipt5 years
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CASS 6.2.15 RSafe custody assets divested by the firm under CASS 6.2.10 RDetails of asset divested, relevant documentation and the firm's attempts to contact the client concernedWhen asset divestedIndefinite
CASS 6.3.2AR (1)Appropriateness of a firm's selection of a third partyGrounds upon which a firm satisfies itself as to the appropriateness of the firm's selection of a third party to hold safe custody assets belonging to clientsDate of the selection5 years (from the date the firm ceases to use the third party to hold safe custody assets belonging to clients)
CASS 6.3.2AR (2)A firm's periodic review into the selection and appointment of a third party under CASS 6.3.1 RDate 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 clientsOn the date of the reviewFive years (from the date the firm ceases to use the third party to hold safe custody assets belonging to clients)
CASS 6.3.6AR(2)Granting of security interests, liens or rights of set-offRecording of the granting of security interests, liens or rights of set-off in the firm’s books and recordsOn the firm’s granting, or where the firm has been informed of the grantingNot specified (see default provision CASS 6.6.7R)
CASS 6.4.3 RDetails of clients and safe custody assets used for the firm's own account or the account of another client of the firmDetails of the client on whose instructions the use of the safe custody assets has been effected and the number of safe custody assets used belonging to each clientMaintain up to date recordsNot specified (see default provision CASS 6.6.7R)
CASS 6.6.2 RSafe custody assets held for each client and the firm's own applicable assetsAll that is necessary to enable the firm to distinguish safe custody assets held for one client from safe custody assets held for any other client, and from the firm's own applicable assetsMaintain up to date recordsNot specified (see default provision CASS 6.6.7R)
CASS 6.6.3 RSafe custody assets held for clientsAccurate records which ensure theircorrespondence to the safe custody assets held for clientsMaintain up to date recordsNot specified (see default provision CASS 6.6.7R)
CASS 6.5.2A R   [deleted]
CASS 6.5.3 R   [deleted]
CASS 6.6.4 RClient specific safe custody asset recordClient specific safe custody asset recordMaintain up to dateNot specified (see default provision CASS 6.6.7R)
CASS 6.6.6RClient agreements that include a firm’s right to use safe custody assets for its own accountA copy of every executed client agreement that includes a firm’s right to use safe custody assets for its own accountNot specifiedNot specified (see default provision CASS 6.6.7R)
CASS 6.6.7RDefault record keeping provisions for CASS 6Refer to the rule concernedRefer 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

CASS 6.6.8 RInternal 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 discrepanciesImmediateNot specified (see default provision CASS 6.6.7 R)
CASS 6.6.16 RAggregate safe custody asset recordAll 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 assetsMaintain up to date if the firm wishes to use the internal custody reconciliation methodNot specified (see default provision CASS 6.6.7 R)
CASS 6.6.30 RRolling stock method for physical asset reconciliationsFirm's reasons for concluding that this method is adequately designed to mitigate risk of records being manipulated or falsifiedBefore using this methodFive years (from the date the firm ceases to use this method)
CASS 6.6.45 RFrequency of the firm's internal custody record checks, physical asset reconciliations and external custody reconciliationsSufficient to show and explain decision taken under CASS 6.6.44 R when determining frequencyImmediate

(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).

CASS 6.6.46R (2)Review of frequency if the firm's internal custody record checks, physical asset reconciliations and external custody reconciliationsDate of each review and the actions the firm took in reviewing the frequency at which it conducts the relevant processImmediateNot specified (see default provision CASS 6.6.7 R)
CASS 6.6.54R (2)(a)Actions taken by the firm to resolve shortfall under this ruleActions taken, description of shortfall, identity of affected client(s), applicable assets appropriated to cover the shortfall. Update when discrepancy resolved.Maintain up to dateNot specified (see default provision CASS 6.6.7 R)
CASS 6.6.54R (2)(b)Actions taken by the firm to resolve shortfall under this ruleActions taken, description of shortfall, identity of affected client(s), amount of money appropriated to cover the shortfall. Update when discrepancy resolved.Maintain up to dateNot specified (see default provision CASS 6.6.7 R)
CASS 6.7.6RAny safe custody asset disposed of in accordance with CASS 6.7.2R

(i) The safe custody asset that was disposed of;

(ii) the value of the consideration received for the safe custody asset disposed of;

(iii) the name and contact details of the client to whom the safe custody asset was allocated, according to the firm’s records at the time of making the record; and

(iv) efforts applied by the firm to determine the client’s correct contact details under CASS 6.7.4E(1)(a) or, if being relied on, for the purposes of CASS 6.2.10R(4).

At the time of the disposalIndefinite
CASS 7.10.3R(3)Record of election to comply with the client money chapterRecord of election to comply with the client money chapter, including the date from which the election is to be effectiveDate of the election5 years (from the date the firm ceases to use the election)
CASS 7.10.31 RRecord of election in relation to CASS 7.10.30RRecord of election in relation to CASS 7.10.30RDate of electionNot specified (see default provision CASS 7.15.5R(3))
CASS 7.10.35 RTrustee firm's election to comply, or to cease to comply, with specific CASS 7 provisionsRelevant provisions, date of election and of any decision to cease to complyWhen election made or decision taken to cease to comply5 years after ceasing to use the election
CASS 7.10.38 RTrustee firm's election to comply, or to cease to comply, with specific CASS 7 provisionsRelevant provisions, date of election and of any decision to cease to complyWhen election made or decision taken to cease to comply5 years after ceasing to use the election
CASS 7.11.3R(3)Written agreement regarding any arrangement relating to a TTCAThe agreementWhen agreement madeFrom the date the agreement is entered into and until five years after the agreement is terminated
CASS 7.11.20RClient's agreement to firm's use of exemption in CASS 7.11.14RClient's written agreementAt the time of client's agreementDuring the time the firm makes use or intends to make use of the exemption in CASS 7.11.14R in respect of that client's monies
CASS 7.11.24RClient’s agreement to firm’s use of the delivery versus payment exemption in CASS 7.11.21RClient’s written agreementAt the time of client’s agreementDuring the time the firm makes use, or intends to make use, of the exemption in CASS 7.11.21R in respect of that client’s monies
CASS 7.11.55 RClient money paid to charity by the firm under CASS 7.11.50R(4)Details of balances released, relevant documentation and the firm's attempts to contact the client concernedWhen balance releasedIndefinite
CASS 7.11.57R (4)Client money paid to charity by the firm under this ruleRecords of all balances released from client bank accounts, including the information in CASS 7.11.55R(1)(a) and CASS 7.11.55R(1)(b)When balance releasedNot specified (see default provision CASS 7.15.5R(3))
CASS 7.13.14BRThe firm’s written policy produced under CASS 7.13.14AR(1)(a) in respect of the firm’s use of client bank accounts under CASS 7.13.13R(3A)(b), and subsequent versions of it

(i) For each of the firm’s business lines, the maximum proportion of the client money held by the firm under CASS 7.13.3R(1) to (3) in respect of the business line that the firm considers would be appropriate to hold in such accounts;

(ii) the firm’s rationale for reaching its conclusion(s) under (i); and

(iii) the means by which the firm will comply with CASS 7.13.14AR(2)(a), having regard to CASS 7.13.14CE.

On the date it creates the version of the policy

Five years after the earlier of:

(1) the date on which the version of the policy was superseded; and

(2) the date on which the firm ceased to use client bank accounts under CASS 7.13.13R(3A)(b).

CASS 7.13.25R(1)Appropriateness of a firm's selection of a third partyGrounds upon which a firm satisfies itself as to the appropriateness of the firm's selection of a third party to hold client moneyDate of the selection5 years (from the firm ceases to use the third party to hold client money)
CASS 7.13.32R(3)Physical receiptsPhysical receipt of moneyWhen the firm receives client money in the form of cash, a cheque or other payable orderNot specified (see default provision CASS 7.15.5R(3))
CASS 7.13.33R(3)Future dated chequeReceipt of moneyWhen the firm receives client money in the form of a cheque that is dated with a future dateNot specified (see default provision CASS 7.15.5R(3))
CASS 7.13.55RFirm's adoption of the alternative approachReasons 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 controlsBefore adopting alternative approachFive years after it ceases to use the alternative approach in connection with that business line
CASS 7.4.19A R to CASS 7.4.19C R   [deleted]
CASS 7.15.2 RClient money held for each client and the firm's own moneyAll 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 moneyMaintain up to date recordsFive years (from the date the record was made)
CASS 7.15.3 RClient money held for each clientAccurate 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 accountsMaintain up to date recordsFive years (from the date the record was made)
CASS 7.15.5R(3)Default record keeping provision for CASS 7Refer to the rule concernedRefer 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

CASS 7.15.18RInternal reconciliation of client money balancesThe firm’s reasons for concluding that the method of internal client money reconciliation it proposes to use meets the criteria at CASS 7.15.18R(1)(a)Before the firm uses a non-standard method of internal client money reconciliation or materially changes its methodNot specified (see default provision CASS 7.15.5R(3))
CASS 7.18.10R(1)Acknowledgment lettersCountersigned acknowledgment letterFrom date of receipt5 years from closure of last account to which the acknowledgment letter relates
CASS 7.18.10R(2)Acknowledgment lettersCopy of acknowledgment letter sent to authorised central counterparty under CASS 7.8.3R (1)From date firm sends the letter5 years from closure of last account to which the acknowledgment letter relates
CASS 7.18.11RAcknowledgment lettersAny other documentation or evidence the firm believes necessary to demonstrate compliance with CASS 7.8None specifiedNone specified (see default provision CASS 7.6.4 R)
CASS 7.10.7ERThe election made under CASS 7.10.7ARThe 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 effectiveAt the time of the election and, if the firm cancels the election, at the time it is cancelledFive years after ceasing to use the election
CASS 7.11.9R (2)Client's communication to firm of wish to terminate TTCAClient's communication of wish to terminate TTCAWhen communication madeFive years (from date of communication)
CASS 7.11.9R (4)Firm's response to client's wish to terminate TTCAFirm's response to client's wish to terminate TTCAWhen notification givenFive years (from date of notification)
CASS 7.11.20 R   [deleted]
CASS 7.11.24 R   [deleted]
CASS 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 moneyDate of reviewFive years (from date of review)
CASS 7.13.25R (3)Firm's periodic review under CASS 7.13.22 R.Fact of review, its considerations and conclusionsDate of reviewFive years (from date of review)
CASS 7.13.36 RUnallocated client moneyFact that the balance treated as unallocated client moneyWhen firm is unable to immediately identify money as client money or its own money and it treats the balance as client moneyPending firm's allocation of the client money concerned to an individual client
CASS 7.13.50 R; CASS 7.13.51 RPrudent segregation recordDetails of money segregated under CASS 7.13.41 R required by these rulesMaintain up to dateFive years (after the firm ceases to retain money as client money under CASS 7.13.41 R)
CASS 7.13.66 R; CASS 7.13.67 RAlternative approach mandatory prudent segregation recordDetails of money segregated under CASS 7.13.65 R required by these rulesMaintain up to dateFive years (after the firm ceases to retain money as client money under CASS 7.13.65 R)
CASS 7.13.74 R; CASS 7.13.75 RClearing arrangement mandatory prudent segregation recordDetails of money segregated under CASS 7.13.73R (3)(a) required by these rulesMaintain up to dateFive years (after the firm ceases to retain money as client money under CASS 7.13.73R (3)(a))
CASS 7.15.5R (1)Total amount of client money the firm should be holding for each clientTotal amount of client money the firm should be holding for each clientMaintain up to dateNot specified (see default provision CASS 7.15.5R (3))
CASS 7.15.5R (2)Transactions and commitments for client moneySufficient to show and explain transactions and commitmentsMaintain up to dateNot specified (see default provision CASS 7.15.5R (3))
CASS 7.15.7 RInternal client money reconciliations and external client money reconciliations conducted carried out by the firmDate, 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 RImmediateNot specified (see default provision CASS 7.15.5R (3))
CASS 7.15.9 RReceipts of client moneyAppropriate 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 accountMaintain up to dateNot specified (see default provision CASS 7.15.5R(3))
CASS 7.15.24 RFrequency of the firm's external client money reconciliationsSufficient to show and explain decision taken under CASS 7.15.23 R when determining frequencyImmediate

(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).

CASS 7.15.26R (2)Review of frequency of the firm's external client money reconciliationsDate of each review and the actions the firm took in reviewing the frequency at which it carries out the external client money reconciliationsNot specifiedNot specified (see default provision CASS 7.15.5R (3))
CASS 7.19.6 RFor each sub-pool established by the firmAll the client beneficiaries of that sub-poolFrom the date on which the sub-pool is createdFive 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 7.19.7 RFor 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-poolFive 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 7.19.8 RFor each sub-pool established by the firmA list of all the sub-pools the firm has created.From the date on which the sub-pool is createdFive 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 7.19.9 RFor each sub-pool established by the firmA sub-pool disclosure documentAt the time of establishing the relevant sub-poolFive 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
CASS 7.19.13R (2)For each sub-pool established by the firmThe name of each client bank account and each client transaction account maintained for the sub-pool, including a unique identifying referenceFrom the date on which the client bank account and client transaction account is maintained for the sub-pool5 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.2.6FRAny balance under CASS 7A.2.6AR(1)(b)(i) or (ii) which has been applied towards any costs incurred in accordance with CASS 7.17.2R or towards any shortfall in the relevant notional pool in accordance with CASS 7A.2.6AR(1)(b) or (c) respectively

(i) The amount of the balance of client money;

(ii) the name and contact details of any client to whom that balance was allocated according to the firm’s records at the time of making the record; and

(iii) efforts applied by the firm to determine the client’s correct contact details under CASS 7A.2.6CE(1)(a) or, if being relied on, for the purposes of CASS 7.11.50R(3).

Immediately before taking steps to apply the balance towards costs or a shortfall in accordance with CASS 7A.2.6AR(1)(b) or (c) respectivelyIndefinite
CASS 7A.3.8R (3)Client money shortfallEach client's entitlement to client money shortfall at the failed bankMaintain up to date recordsUntil client is repaid
CASS 7A.3.10R (3)Client money shortfallEach client's entitlement to client money shortfall at the failed bankMaintain up to date recordsUntil client is repaid
CASS 7A.3.11R (3)Client money shortfallEach client's entitlement to client money shortfall at the failed bankMaintain up to date recordsUntil client is repaid
CASS 7A.3.17R (3)Client money shortfallEach client's entitlement to client money shortfall at the failed intermediate broker, settlement agent or OTC counterpartyMaintain up to date recordsUntil client is repaid
CASS 8.3.1 RAdequate records and internal controls in respect of the firm's use of mandates (see CASS 8.3.2 R to CASS 8.3.2C R )Up to date list of firm's mandates and any conditions regarding the use of mandates, all transactions entered into, details of procedures and internal controls for giving and receiving of instructions under mandates, and important client documents held by the firm, and, in relation to non-written mandates, the further details required by CASS 8.3.2C RMaintain current full detailsOne 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 date
CASS 10.1.3 RA firm's CASS resolution packThe documents to which CASS 10.2 and CASS 10.3 referFrom the date on which a firm becomes subject to CASS 10.1.3 RNone is specified
CASS 10A.1.3RA safeguarding institution's CASS resolution packThe records set out in CASS 10A.2 and CASS 10A.3When CASS 10A comes into forceNot specified (see default provision CASS 15.8.8R(3))
CASS 11.3.6 RAllocation 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 RThe person to whom (as applicable) the CASS oversight responsibilities have been allocated, or to whom the CASS operational oversight function has been allocatedUpon allocation5 years (from the date the record was made)
CASS 11.7.6 RAppropriateness of a CASS large debt management firm's selection of an approved bankGrounds 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 moneyDate of the selection5 years (from the date the firm ceases to use the approved bank to hold client money)
CASS 11.8.8 RClient bank account acknowledgement letters sent in accordance with CASS 11.8.2 REach countersigned client bank account acknowledgement letters receivedOn receipt of each letter5 years (following closure of the last client bank account to which the letter relates)
CASS 11.8.9 RDemonstration that a CASS debt management firm has complied with CASS 11.8.2 R to CASS 11.8.7 REvidence of such complianceOn compliance with the relevant provisionNone specified
CASS 11.9.5 RMoney received from clients in the form of cash, cheques or other payable ordersDetails of money receivedOn receiptNone specified
CASS 11.9.8 R (2)Unidentified client money under CASS 11.9.8 R (2)Details of unidentified client money heldBeing unable to identify money as client money or its own money, and deciding it is reasonably prudent to so recordUntil it performs the necessary steps to identify the money under CASS 11.9.8 R (1)
CASS 11.11.1 RClient money held for each client and the CASS debt management firm's own moneyAll 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 moneyMaintain up-to-date recordsNone is specified
CASS 11.11.3 RClient money held for each clientAccurate 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 accountsMaintain up-to-date recordsNone is specified
CASS 11.11.4 RPayments made to, for or on behalf of clients by a CASS debt management firm and written and oral contact with clients and creditorsDetails of payments made and of the written or oral contactMaintain up-to-date recordsNone is specified
CASS 11.12.4 RA CASS debt management firm's CASS 11 resolution packThe 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 RNone is specified
CASS 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 eventDetails of the shortfallOn the secondary pooling event occurringNone is specified
CASS 13.2.3RAllocation of oversight function in CASS 13.2.3RThe person to who the oversight function is allocatedUpon allocation5 years (from the date the record was made)
CASS 13.5.8R Client bank account acknowledgement letters sent in accordance with CASS 13.5.2REach countersigned client bank account acknowledgement letter receivedOn receipt of each letter5 years (following closure of the last client bank account to which the letter relates)
CASS 13.5.9RDemonstration that the firm has complied with the requirements of CASS 13.5Evidence of such complianceOn compliance with the relevant provisionNone specified
CASS 13.6.5RMoney received from customers in the form of cash, cheques or other payable ordersDetails of money receivedOn receiptNone specified
CASS 13.6.6R(2)Unidentified client money under CASS 13.6.6R(2)Details of unidentified client money heldBeing unable to identify money as client money or its own money, and deciding it is reasonably prudent to so recordUntil it performs the necessary steps to identify the money under CASS 13.6.6R(1)
CASS 13.10.1R(1)Client money held for each customer and the firm’s own moneyAll that is necessary to enable the firm to distinguish client money held for one customer from client money held for any other customer and from the firm’s own moneyMaintain up-to-date recordsNone specified
CASS 13.10.3RClient money held for each customerAccurate records to ensure the correspondence between the records and accounts of the entitlement of each customer for whom the firm holds client money with the records and accounts of the client money the firm holds in client bank accountsMaintain up-to-date recordsNone is specified
CASS 13.10.4RPayments made to, for or on behalf of customers by the firmDetails of payments madeMaintain up-to-date recordsNone is specified
CASS 13.11.13RA record of each customer’s shortfall in the event of a secondary pooling eventDetails of the shortfallOn the secondary pooling event occurringNone is specified
CASS 15.2.5R(2)Unallocated relevant fundsBalance of unallocated relevant fundsPending allocation of relevant funds to individual clientsUntil relevant funds allocated to individual clients
CASS 15.2.9R(2)Unidentified relevant fundsBalance of unidentified relevant fundsWhen a safeguarding institution is unable to identify whether funds are relevant fundsUntil funds identified as either relevant funds or other funds
CASS 15.4.11R(1)Use of third party to manage relevant assetsGrounds upon which the safeguarding institution chose the third party, and periodic reviews of appointment and selectionWhen selection made or review completedNot specified (see default provision CASS 15.8.8R(3))
CASS 15.6.7R(1)Use of third parties for safeguarding purposesGrounds upon which the safeguarding institution chose the third party, and periodic reviews of appointment and selectionWhen selection made or review completedNot specified (see default provision CASS 15.8.8R(3))
CASS 15.7.10RAcknowledgement lettersCountersigned acknowledgment lettersWhen receivedFive years from when the last account the letter relates to is closed
CASS 15.7.11RRequirements relating to acknowledgement lettersDocumentation or evidence to demonstrate compliance with requirementsWhen identifiedNot specified (see default provision CASS 15.8.8R(3))
CASS 15.8.3R(1)Relevant funds and other fundsSuch records and accounts as are necessary to enable a safeguarding institution to distinguish between relevant funds and fundsMaintain up to date recordsNot specified (see default provision CASS 15.8.8R(3))
CASS 15.8.8R(1)Relevant fundsSuch records as are sufficient to allow a safeguarding institution to determine the total amount of relevant funds it should be holding for each of its clientsMaintain up to date recordsNot specified (see default provision CASS 15.8.8R(3))
CASS 15.8.8R(3)Default record keeping requirement for CASS 15Refer to the rule concernedRefer to the rule concerned

Five years from the later of:

(1) the date it was created; or

(2) the date it was most recently modified.

CASS 15.8.9RInternal safeguarding reconciliation and external safeguarding reconciliationThe time and date it carried out the relevant process; the actions it took in carrying out the relevant process; the outcome of its calculation of its safeguarding requirement and, where relevant, safeguarding resource; and, where relevant, the outcome of its comparison of its D+1 segregation requirement and D+1 segregation resourceWhen reconciliation carried outNot specified (see default provision CASS 15.8.8R(3))
CASS 15.8.11R(2)Daily calculation of safeguarding requirement for a safeguarding institution that uses an insurance policy or guarantee providing unlimited coverDate of calculation, actions that the safeguarding institution took and the outcome of the calculationDailyNot specified (see default provision CASS 15.8.8R(3))
CASS 15.8.22R(1)Reconciliation pointsThe reconciliation point(s) that will be used for internal safeguarding reconciliationsWhen selectedNot specified (see default provision CASS 15.8.8R(3))
CASS 15.8.22R(1)Internal safeguarding reconciliationsThe frequency of internal safeguarding reconciliationsWhen determinedNot specified (see default provision CASS 15.8.8R(3))
CASS 15.8.37R(1)(a)Non-standard method of internal safeguarding reconciliationReason for concluding the method of internal safeguarding reconciliation satisfies the requirements