BBA has responded to FSA's proposals for implementing the Client Money and Asset Return (CMAR) for large and medium-sized firms. Its main concern is that there will not be long enough between FSA's publication of the final CMAR rules and guidance and the date on which they take effect to allow firms to prepare. It also says FSA must consider how the requirements interact with other reporting requirements and to clarify whether the holders of the new controlled function 10a must review and submit the CMAR themselves or can delegate the submission where appropriate. It is also concerned FSA requires reporting in sterling, when many firms meet their obligations exclusively in US Dollars. (Source: BBA response on operational implementation of CMAR for medium and large firms)