Client money and assets

Find out how to follow our client assets rules, including sending us a return about your client assets.

You must follow rules set out in the Client Assets Sourcebook (CASS) whenever you hold or control client money or safe custody assets as part of your business.

This is to keep client money and assets safe if firms fail and exit the market.

To reduce the risk of financial loss, you should:

  • identify risks
  • assess risks
  • mitigate (reduce) risks

Firms holding or controlling client assets must report the value of their assets. This includes:

  • brokers
  • investment banks
  • custodians

CASS classification

Your CASS firm type (small, medium or large) is based on the size of your client money or custody asset holdings (or both).

Your firm must make an annual notification about the money and assets you hold to identify if you are small, medium or large. This will enable you to see what your firm’s classification will be (see CASS 1A.2).

 

CASS firm type Highest total amount of client money held in the firm's last calendar year or that you project it will hold during the current calendar year Highest total value of safe custody assets held in the firm's last calendar year or that you project it will hold during the current calendar year
CASS large firm more than £1 billion more than £100 billion
CASS medium firm an amount equal to or greater than £1 million and less than or equal to £1 billion an amount equal to or greater than £10 million and less than or equal to £100 billion
CASS small firm less than £1 million less than £10 million

CASS classification questionnaire

You must complete the CASS classification questionnaire every year within 15 working days of 31 December.

We email this in December to your firm’s:

  • director or senior manager responsible for CASS (known as CF10a or SMF18), or
  • principal user of the Gabriel online system

If you reported a zero balance in the previous calendar year, you must still complete the questionnaire. 

CASS small firms don’t need to complete a Client Money and Asset Return (CMAR).

What CASS medium or large firms must do

If your firm is or becomes a CASS medium or large firm holding client money equal to or over £1 million and/or assets equal to or over £10m, you must:

  • complete a CMAR
  • make a director or senior manager responsible for CASS (CF10a or SMF18)

Complete a monthly Client Money and Asset Return (CMAR)

You must complete a CMAR via Gabriel every month.

This gives us an overview of your client money and safe custody assets.

Loan-based crowdfunding firms

If your firm operates loan-based crowdfunding, you may need to follow certain CASS rules.

See the summary of rules for loan-based crowdfunding platforms for more information.

Contact us

For general client money and asset enquiries, email [email protected].

For queries about requirements in the Client Assets sourcebook, email [email protected].

For breach notifications, email [email protected].

CASS asset audit reports should be submitted through our preferred method via Connect. See our user guide for details on how to do this.

Or write to: Client Assets and Resolution Department, Financial Conduct Authority, 12 Endeavour Square, London, E20 1JN.

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