New rules in relation to the CASS firm classification and operational oversight regime, client money and assets return (CMAR) and mandate rules have been published by the FSA this month in Policy Statement 12/20 (PS12/20).
The FSA has decided to implement the original proposals that were consulted on in July 2012 (CP 12/5). This includes providing additional clarification on the scope of CASS 1A and introducing a more flexible opt-in provision to allow a CASS small firm or CASS medium firm to be treated as a CASS medium firm or CASS large firm at any point.
In relation to CMAR, the FSA has made only minor modifications to the proposals in CP 12/5, including modifying the guidance to specify that client money balances should be taken from internal records. A revised template for CMAR is attached to the policy statement. The FSA has taken forward its proposals to clarify the scope of the mandate rules and goes on to provide some additional guidance on these rules.
The majority of the new rules will come into force on 1 January 2013. The technical changes to CMAR and the related guidance notes will come into force on 28 February 2013.