The Client Money and Assets (CASS) Blueprint: For CASS 6 & 7 Firms

Product Information

CASS applies directly in respect of activities conducted with or for all categories of clients. 2 2 DEPP 6A.3 Determining the appropriate length of the period of suspension, restriction, condition or disciplinary prohibition

FEES TP 2 Transitional provisions relating to changes to the FSCS levy arrangements taking effect in 2007/8 and in 2008/9 MIFIDPRU 3 Annex 1 Application under MIFIDPRU 3.3.2R - permission to include interim or year-end profits as CET1 it should do so in compliance with CASS 5.5.80 R and a transferee firm will come under an obligation to treat CONC App 1.4 Exemption for high net worth borrowers and hirers and exemption relating to businesses

Loan-based crowdfunding firms

SUP 6.3 Applications for variation of permission and/or imposition, variation or cancellation of requirements MIFIDPRU 3 Annex 5 Notification under MIFIDPRU 3.6.3R - intended reduction in own funds instruments where a condition in MIFIDPRU 3.6.4R applies SUP 10A Annex 7 Form D: Notification of changes in personal information or application details and conduct breaches/disciplinary action related to conduct [deleted] You should therefore ensure that you are aware of all the latest requirements under CASS. You should be mindful that the FCA is likely to take any failure to comply as serious. Conclusion Dear CEO letter: Adequate client assets arrangements (for firms holding client assets relating to investment business, debt management or claims management).

EG 19.14 The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 is no further modification of the rules in the chapters referred to in (4) for activities carried on for eligible counterparties. Such clients are treated in the same way as other professional clients for the purposes of these rules. COBS 2.2 Information disclosure before providing services (other than MiFID and insurance distribution) MIFIDPRU 5 Annex 1 Notification under MIFIDPRU 5.6.3R and 5.9.3R that limits for concentration risk have been exceededMIFIDPRU 2.7 Investment holding companies, mixed financial holding companies and mixed-activity holding companies This paragraph (5) explains how CASS 13.2.3R applies to a limited scope SMCR firm. Most firms carrying on a regulated claims management activity will be limited scope SMCR firms. BENCH 2 Parts of the Handbook applicable to regulated benchmark administrators and benchmark contributors

SUP 12.8 Termination of a relationship with an appointed representative or FCA registered tied agent CONC 7.3 Treatment of customers in default or arrears (including repossessions): lenders, owners and debt collectors COBS 6.1 Information about the firm and compensation information (non-MiFID and non-insurance distribution provisions) DISP 1 Annex 4 Appropriate wording for inclusion in a final response, written acceptance or summary resolution communication

CASS classification

If your business model does involve holding client assets, you should ensure that you have permission to do this. You must then ensure that you are fully complying with your obligations under CASS. Are there other financial activities which involve CASS obligations? The senior managers and certification regime is summarised in SYSC 23.3 (Overview of the senior managers and certification regime). FEES 13A Temporary Permissions Regime (TPR) and Financial Service Contracts Regime (FSCR) – Illegal money lending levy