The FSA has published a Consultation Paper (CP12/15) on its Client Assets Sourcebook (CASS) rules, making a number of proposals in relation to CASS firm classification and operational oversight, client money and assets returns (CMAR) and the mandate rules.

The Consultation Paper sets out the FSA's proposal to clarify that the regulated activity of arranging safeguarding in administration of assets does not fall within the scope of CASS 1A. It also proposes to clarify the date when a firm becomes a CASS firm for the first time and the point at which a CASS firm changes category. The paper outlines the FSA's intention to introduce a more flexible opt-in provision to allow small or medium-sized CASS firms to be treated as a medium or large-sized CASS firms at any given point throughout the course of the year.

With regards to CMAR, the FSA has proposed to include amendments to the table in section 6 to avoid unnecessary double reporting of stock holdings, in addition to new guidance which standardises the use of internal reconciliations when reporting client money balances.

Responses to CP12/15 should be sent to the FSA before 30 September 2012.