Whilst on the topic of client money a reminder that from 1 October all CASS medium and large firms have had to have an individual approved for the CASS oversight function (CF10a). From the same date such firms will also have to complete a Client Money and Asset Return (CMAR) on a monthly basis.
In terms of client money, any firm holding less than £1m will be classified as a CASS small firm and will not need to apply for a CF10a but will need to allocate an individual to have CASS operational oversight. For the avoidance of doubt, the CMAR obligation does not yet extend to such small firms. Please see Regulatory Roundup 30 for further details.
Note that the individuals approved for CF10a are not currently shown on the FSA Register and instead appear on separately maintained lists.