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[PLEASE NOTE: We have included a ready-to-use Resolution Pack in an Excel format with your manual. Completing that Excel document enables you to comply with many of the CASS 10.2, 10.3 and 11.12 requirements, along with inserting the additional documentation into your pack (e.g. letters, agreements, reconciliations etc).
However, some firms may prefer to use Word templates for their RP, so we have added some templates below that can be used. You do not need complete both versions. One of each Word template document should be completed for each institution, client, agent and/or third-party if you are not using the Excel format. The Master Document below is a duplication of the Excel version and does not need adding to a RP if already using the full Excel provision.]
1 CASS 10 Resolution Pack Master
Document
This table provides a list of the required CASS Resolution Pack (RP) contents and acts as the Master Document for noting the location of each document, its retrieval deadline and when the document was last updated or reviewed.
| DOCUMENT (CASS REQUIREMENT) | CASS REF | RETRIEVAL TIME | RETRIEVAL NOTES | LOCATION IF NOT IN RP | INCLUDED IN RP | LAST REVIEW | |
| Details of document or information to be included in the RP | Information needed to retrieve the document/data | Electronic/physical location | YES | NO | Add date | ||
| Master document containing information sufficient to retrieve each document in the firm’s CASS resolution pack | 10.2.1 R (1) | 48 hours | |||||
| A document which identifies the institutions the firm has appointed (including through an AR, tied agent, field representative or other agent) for the placement of money, to hold client money and for the deposit of safe custody assets | 10.2.1 R (2) | Immediate | |||||
| A document which identifies each AR, tied agent, field representative or other agent of the firm which receives client money or safe custody assets in its capacity as the firm’s agent | 10.2.1 R (3) | 48 hours | |||||
| A document which identifies each senior manager, director or other individual responsible for the performance of any CASS obligation or operational function and the person who has been given the responsibility for CASS operational oversight or to whom the CASS operational oversight function has been allocated | 10.2.1 R (4) | Immediate | |||||
| For each institution identified in CASS 10.2.1R (2), a copy of each executed agreement, (including letters or agreements to clarify/modify terms) between that institution and the firm in relation to the holding of client money or safe custody assets | 10.2.1 R (5) | 48 hours | |||||
| For each institution identified in CASS 10.2.1R (2), a copy of any written notification or acknowledgement letters sent or received pursuant to CASS 7.18 | 10.2.1 R (5) | Immediate | |||||
| A document which identifies each member of the firm’s group (listing type of entity) or any third party used by the firm, who are involved in operational functions related to any obligations imposed under CASS 6 or CASS 7 | 10.2.1 R (6) | 48 hours | |||||
| A copy of each executed agreement, (including letters or agreements to clarify/modify terms), between the firm and each third party identified in 10.2.1 R (6) | 10.2.1 R (7) | 48 hours | |||||
| Where the firm relies on a third party identified in 10.2.1 R (6), a document which describes how to gain access to relevant information held by that third party and effect a transfer of any of the client money or safe custody assets held by the firm, but controlled by that third party | 10.2.1 R (8) | 48 hours | |||||
| A copy of the firm’s manual in which are recorded its procedures for the management, recording and transfer of the client money and safe custody assets that it holds | 10.2.1 R (9) | 48 hours | |||||
| A record of the grounds upon which the firm satisfied itself as to the appropriateness of its selection and appointment of a third party under CASS 6.3.1 R and a record of each conducted periodic review of its selection and appointment of the third party. | CASS 6.3.2A R | 48 hours | |||||
| Where a firm uses safe custody assets, a record to include details of the client on whose instructions the use of the safe custody assets has been affected and the number of safe custody assets used, belonging to each client who has given consent | CASS 6.4.3 R | 48 hours | |||||
| Records and accounts to immediately distinguish safe custody assets held for one client from another, and from the firm’s own assets, maintained in a way that ensures their accuracy, and in particular their correspondence to the safe custody assets held for clients | CASS 6.6.2 R
& CASS 6.6.3 R |
Immediate | |||||
| A copy of every executed client agreement that includes that firm’s right to use safe custody assets for its own account, including disclosure annexes from prime brokerage agreements | CASS 6.6.6 R | 48 hours | |||||
The most recent: –
|
CASS 10.3.1R (3)
CASS 10.3.1R (5) CASS 10.3.1R (7/A) CASS 10.3.1R (7A) |
Immediate | |||||
| For each internal custody record check, physical asset reconciliation and external custody reconciliation, a record which includes: –
a) the date it carried out the relevant process b) the actions the firm took in carrying out the relevant process c) a list of any discrepancies the firm identified, and the actions taken to resolve those discrepancies |
CASS 6.6.8 R | 48 hours | |||||
| Adequate policies and procedures sufficient to ensure compliance with its obligations under the regulatory system for carrying out record checks and reconciliations | SYSC 6.1.1 R | Immediate | |||||
| A record of the grounds upon which the firm satisfied itself as to the appropriateness of its selection and appointment of a bank or a qualifying money market fund under CASS 7.13.8 R.
A record of each periodic review conducted of its selection and appointment of a bank or a qualifying money market fund with its considerations and conclusions. A record of each periodic review (inc considerations and conclusions), conducted under CASS 7.13.22 R, to periodically assess whether it is appropriate to diversify the third parties used to deposit the client money held by the firm |
CASS 7.13.25 R | 48 hours | |||||
| Records and accounts to immediately distinguish client money held for one client from another, and from the firm’s money, maintained in a way that ensures their accuracy, and in particular their correspondence to the client money held for client | CASS 7.15.2 R
& CASS 7.15.3 R |
Immediate | |||||
| Records to promptly determine the total amount of client money it should be holding for each of its clients, explaining transactions and commitments for its client money | CASS 7.15.5 R | Immediate | |||||
| For each internal client money reconciliation and external client money reconciliation conducted, a record detailing: –
a) the date it carried out the relevant process b) the actions the firm took in carrying out the relevant process c) the outcome of its calculation of its client money requirement and client money resource |
CASS 7.15.7 R | Immediate | |||||
| A record in relation to each client of the categorisation established for the client under this COBS 3.8, including sufficient information to support that categorisation | COBS 3.8.2 R (2)(a) | 48 hours | |||||
| A copy of any agreement entered into with the client under COBS 3.8 | COBS 3.8.2 R (2)(c) | 48 hours | |||||
| A record that includes the document/s agreed between the firm and a client, setting out the rights and obligations of the parties, and other terms on the provision of services to the client | COBS 8.1.4 R | 48 hours | |||||