Following FSA’s decision to introduce the Client Money and Asset Return (CMAR), it is now consulting on how to implement it. It plans to use a phased approach and to use the GABRIEL reporting system. FSA wants the approximately 400 CASS medium and large firms to complete the CMAR in line with its original timetable for implementation and, once its processes are in place properly to collect and analyse the data it receives, it will extend the system to the approximately 1,200 CASS small firms. Reporting would be on a half-yearly basis. However, as an interim measure, it plans to require CASS small firms to notify it of their highest client money balances and safe custody asset value in the previous reporting period, again on a half-yearly basis. FSA wants comments on in its implementation plans for CASS medium and large firms by 10 April, and the rules come into force on 1 June. But it wants comments on its suggestions for CASS small firms by 10 March. (Source: Consultation Paper CP11/4**: The Client Money and Asset Return (CMAR): Operational Implementation)