How the new client money rules affect your firm

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1 How the new client money rules affect your firm High quality professional advice and expert insight in client money February 2015

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3 Introduction Overview of the proposed changes to the CASS rules in Policy Statement 14/09. In June 2014 the Financial Conduct Authority (FCA) issued Policy Statement 14/09 which announced a wide range of changes including but not limited to: custody assets reconciliations delivery versus payment exclusion recordkeeping and reconciliations acknowledgement of trust letters. We summarise each key topic within the document on pages 5 and 6 and then discuss each in further detail describing the impact to firms from page 6 onwards. This material is extracted and summarised from the policy statement and set out in logical groupings for ease of reference. When the new rules will apply The changes set out in the Policy Statement apply in stages. Some rule changes are already in effect as of July and December 2014 (the latter mainly for new business which firms conduct). The remaining changes come into effect from 1 June 2015 for existing business relationships. Firms should be aware that in certain sections of the handbook, the rules were renumbered in December 2014 and there will be further renumbering in June This may entail the firm undertaking new mappings of the rules to ensure that they keep track of the relevant rules in a given timeframe. What action you need to take The changes set out in the Policy Statement affect a wide variety of firms across the financial services industry, excluding insurers. The rules concerning acknowledgement of trust letters, due diligence, unclaimed assets and transfers of business could affect most firms regardless of industry sector. Other rules regarding the alternative approach, use of buffers, delivery versus payment exclusion, and custody reconciliations will apply to some firms but not others. In an important change the CASS 7 Annex 1 has been replaced with a new chapter Firms should carefully study the clarifications which the FCA have issued in respect of how firms should calculate the client money requirement, for example the amount of money the firm should appropriate and segregate as client money to cover an unresolved shortfall. Firms should assess for themselves which rule changes will impact their business. We would expect that firms will now have in place programmes to assess, design and then implement the changes which they consider are necessary to comply with the revised rulebook. We consider that the impacts require firms, amongst other things, to revisit their terms of business, client disclosures, client money and assets policies and even the functioning of technology tools which calculate segregation amounts and provide MI. Client asset governing bodies need to ensure that arrangements have been put in place to provide assurance that their firm is on track to implement required changes in the prescribed timeframe. Finally firms should take note of the fact that the FCA require auditor assurances in respect of a number of internal systems and controls as a result of these new regulations. HOW THE NEW CLIENT MONEY RULES WILL AFFECT YOUR FIRM 3

4 How we can help you prepare for the new rules Our services Grant Thornton s CASS specialist team has extensive experience working with clients across the investment management, investment banking, wealth management, brokerage, custody, and platform sectors. Our detailed knowledge of the operational complexities at firms and their administrators, combined with our close working relationship with the FCA means that we bring practical as well as technically robust assessments to each of the firms with whom we perform CASS work. Paul Garbutt Partner T +44 (0) E Chris Golland Senior Manager T +44 (0) E We have set out below some of the ways in which Grant Thornton can support your firm as you implement the changes required by PS 14/9: we can help your firm undertake structured reviews to determine whether the firm is compliant with the new rules set out in this publication we can bring to you practical and insightful advice relating to the required changes to operational systems and controls we can design and deliver remediation plans we understand the FCA s expectations around good governance and can provide you and your CF10a with support to build, enhance or redesign current governance structures and supporting MI in light of the changes necessary from the PS we regularly provide training and awareness workshops to firms ranging from one-to-one in depth discussions to group workshops to high level executive sessions covering key CASS principles. Paul Staples Senior Manager T +44 (0) E Owen Leathem Manager T +44 (0) E Rukaiya Rashid Manager T +44 (0) E If you would like to discuss how we can help you in more detail please get in touch. 4 HOW THE NEW CLIENT MONEY RULES WILL AFFECT YOUR FIRM

5 EXECUTIVE SUMMARY

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7 Executive summary Policy topic Summary of changes Effective date CASS 6 Custody Assets Reconciliations CASS 6 Other CASS 6 and 7 Delivery Versus Payment Exclusion CASS 6 and 7 Unclaimed Money and Assets Internal custody reconciliation choice of methods introduced at least monthly Physical asset reconciliation External custody reconciliation Determining frequencies for custody record checks and reconciliations Handling discrepancies and shortfalls in custody assets Recordkeeping, record checks and reconciliations Registration of custody assets Written custody agreements Transactions through a commercial settlement system. Exemption from client money rules until third business day. Introduce written agreement with clients Regulated collective investment schemes ( CIS ). Window reduced to one day for authorised fund managers. Introduce written agreement with clients There is now more clarity and prescription associated with gone aways Prescribed steps taken to contact client De minimis amounts Onus on firm to check legal position requires unconditional undertaking Paid to charity not to the firm Six years since last movement All associated costs to be borne by firm 1 June 2015 May comply before this date 1 June 2015 (1 Dec 2014 new business) 1 June 2015 (1 Dec 2014 new business) 1 June Dec 2014 CASS 7 Banking Exemption Operation of the Banking Exemption notifications to clients 1 Dec 2014 CASS 7 Trustee firms Application 1 July 2014 CASS 7 Transfers of Business Transfer clauses Post transfer notifications 1 Dec Dec 2014 HOW THE NEW CLIENT MONEY RULES WILL AFFECT YOUR FIRM 5

8 Policy topic Summary of changes Effective date CASS 7 Immediate Segregation CASS 7 Physical Receipts and Allocation of Client Money CASS 7 Alternative Approach CASS 7 Recordkeeping and Reconciliations CASS 7 Acknowledgement Letters CASS 7 Client Bank Accounts CASS 7 Money Held by Third Parties CASS 7 Other Issues Interaction with the EMIR for firms that are members of CCPs clearing arrangement mandatory prudent segregation amount Interaction with the DvP window for transactions in settlement systems Prudent Segregation Paying physical receipts into a client bank account Cleared funds Allocation of client money receipts Firms use of the alternative approach Auditor assurances Obtaining revised auditor reports Intra-day adjustments External client money reconciliations Internal client money reconciliations Non-standard methods of internal client money reconciliation Standard methods of internal client money reconciliation Acknowledgment letters and template letters Overseas counterparties Removal of 20-business day grace period Authorised central counterparties (CCP) Recordkeeping and periodic reviews Establishing signatory authority/electronic signatures Overnight money market deposits Diversification Due diligence Client money held by third parties Client money relating to custody assets of custodians Interest Money ceasing to be client money Unbreakable client money term deposits Commodity Futures Trading Commission Part 30 Exemption Order 1 June June June 2015 (1 Dec 2014 new business) 1 June June 2015 for repapering existing letters Templates must be in place for accounts opened after 30 November June Dec June July 2014 CASS 8 Non-written mandates 1 June 2015 CASS 9 CASS 7, 7A Multiple Client Money Pools Regular reporting to clients (on client assets) Information to clients on client assets protection arrangements Operational complexity and litigation risk Operating multiple client money pools Diversification Operating multiple client money pools Sub-pool disclosure document Operation of immediate segregation in the context of sub-pools 1 Dec June July HOW THE NEW CLIENT MONEY RULES WILL AFFECT YOUR FIRM

9 CHANGES RELEVANT TO CASS 6 Custody assets reconciliations Internal custody reconciliation 7 Physical asset reconciliation 8 External custody reconciliation 9 Determining frequencies for custody record checks and reconciliations 10 Handling discrepancies and shortfalls in custody assets 11 Custody asset recordkeeping, record checks and reconciliations 12

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11 Custody assets reconciliations INTERNAL CUSTODY RECONCILIATION Custody rules (CASS 6) (Deadline 1 June 2015) Current rules Investment firms are required to maintain records of custody assets in a manner which ensures their accuracy, and that they correspond with the custody assets they hold. Internal and external reconciliations should be carried out as often as necessary and as soon as practicable after the date of the reconciliation. Any discrepancies identified through the reconciliation process must be corrected promptly. Firms must also correct and make good any shortfall in custody assets where there are reasonable grounds for concluding that the firm is responsible for the shortfall. FCA has observed frequent occurrences of firms having poor record-keeping practices, and inadequate systems and controls to ensure the accuracy of records. FCA also consider that many firms do not understand their requirements in respect of custody asset recordkeeping, record checks and reconciliations. FCA are aware that firms using integrated systems to keep their custody records may not be able to carry out internal custody reconciliations, as it is not possible to extract two independent records from such a system. Consequently these firms will be required to carry out an internal custody record check. All firms must perform internal custody record checks as regularly as necessary, but at least monthly, to ensure that their records of safe custody assets correspond with their obligations to clients for holding safe custody assets. Internal custody record checks must be carried out by one of two methods: 1) Internal custody reconciliation method: a comparison on a particular date between two separately maintained records (which need not be independent of one another) to ensure that the firm s records of its safe custody assets correspond with its obligations to clients to hold safe custody assets: a) a client-specific safe custody asset record ; and b) an aggregate safe custody asset record ; OR 2) Internal system evaluation method: a process to evaluate: (a) the completeness and accuracy of the firm s internal records and accounts of custody assets held for clients including whether sufficient information is being recorded by the firm to enable it to identify a client-specific safe custody asset record, and readily determine the total of all custody assets held for clients; and (b) whether the firm s systems and controls correctly identify and resolve all discrepancies in its internal records and accounts of custody assets it holds for its clients (including identification of any negative balances, test data or balancing entries, IT processing or journal entry errors). All firms, regardless of type and business model, will be permitted to undertake their internal custody record checks by way of the internal system evaluation method. Firms will be permitted to undertake these processes without first seeking a confirmation or any other report from an independent auditor. The processes will be reviewed by the auditor in the annual client assets report. Firms will need to review their processes and procedures to ensure that they will be able to comply with the new regulations. HOW THE NEW CLIENT MONEY RULES WILL AFFECT YOUR FIRM 7

12 Custody assets reconciliations PHYSICAL ASSET RECONCILIATION Custody rules (CASS 6) (Deadline 1 June 2015) Current rules Investment firms are required to maintain records of custody assets in a manner which ensures their accuracy, and that they correspond with the custody assets they hold. Internal and external reconciliations should be carried out as often as necessary and as soon as practicable after the date of the reconciliation. Any discrepancies identified through the reconciliation process must be corrected promptly. Firms must also correct and make good any shortfall in custody assets where there are reasonable grounds for concluding that the firm is responsible for the shortfall. FCA has observed frequent occurrences of firms having poor record-keeping practices, and inadequate systems and controls to ensure the accuracy of records. FCA also consider that many firms do not understand their requirements in respect of custody asset recordkeeping, record checks and reconciliations. FCA are aware that firms using integrated systems to keep their custody records may not be able to carry out internal custody reconciliations, as it is not possible to extract two independent records from such a system. Consequently these firms will be required to carry out an internal custody record check. All firms that physically hold custody assets must undertake a physical asset reconciliation as often as necessary, but at least every six months. This comprises a comparison between a firm s internal records and a count of the actual physical safe custody assets it holds for its clients, performed by one of two methods: total count method the count being of all physical custody assets held by the firm on a particular date; and rolling stock method the count of all physical custody assets held by the firm being undertaken in more than one stage, with each stage referring to a count of a line of stock or group of stock lines (eg all the securities held in connection with a particular business line being counted at the same time). Before using the rolling stock method, firms must document their reasons for concluding that they have systems and controls in place that will effectively mitigate the risk of its records being manipulated (eg teeming and lading ). Firms will be permitted to use either of the physical count methods without first obtaining a written report on the adequacy of the proposed method from an independent auditor. However, review of the method used will be a requirement of the annual auditor s client assets report. Firms will need to ensure that they have systems and procedures which enable them to fulfil the physical count requirements. Firms carrying out the rolling stock method will need to ensure that they have appropriate documentation in place setting out why they consider their systems and controls are adequate. Fees for the annual auditor s client assets report can also be expected to increase due to the extra time requirement. 8 HOW THE NEW CLIENT MONEY RULES WILL AFFECT YOUR FIRM

13 Custody assets reconciliations EXTERNAL CUSTODY RECONCILIATION Custody rules (CASS 6) (Deadline 1 June 2015) Current rules Investment firms are required to maintain records of custody assets in a manner which ensures their accuracy, and that they correspond with the custody assets they hold. Internal and external reconciliations should be carried out as often as necessary and as soon as practicable after the date of the reconciliation. Any discrepancies identified through the reconciliation process must be corrected promptly. Firms must also correct and make good any shortfall in custody assets where there are reasonable grounds for concluding that the firm is responsible for the shortfall. FCA has observed frequent occurrences of firms having poor record-keeping practices, and inadequate systems and controls to ensure the accuracy of records. FCA also consider that many firms do not understand their requirements in respect of custody asset recordkeeping, record checks and reconciliations. FCA are aware that firms using integrated systems to keep their custody records may not be able to carry out internal custody reconciliations, as it is not possible to extract two independent records from such a system. Consequently these firms will be required to carry out an internal custody record check. The changes comprise a number of clarifications as to how external custody reconciliations should be carried out. The reconciliations must be performed as regularly as necessary, but at least monthly. They must be carried out between the firm s internal records and those provided by the relevant third party being the entity with whom the firm deposits custody assets; or with whom it registers custody assets (as the case may be for instance operators of collective investment schemes). The third party s records for the purpose of carrying out the external custody reconciliation may comprise any appropriate information (including statements or other confirmations). Where firms hold physical custody records such as paper share certificates, they are not required to undertake external custody reconciliations in respect of the relevant assets. However, firms would be expected to carry out periodic spot checks on whether title to an appropriate sample of custody assets they hold is registered in accordance with the CASS rules. Firms should ensure that they are carrying out external reconciliations as required, and at least monthly. Firms which physically hold custody assets should establish procedures for carrying out periodic spot checks on whether title to an appropriate sample of physical custody assets has been registered correctly. HOW THE NEW CLIENT MONEY RULES WILL AFFECT YOUR FIRM 9

14 Custody assets reconciliations DETERMINING APPROPRIATE FREQUENCIES FOR CUSTODY RECORD CHECKS AND RECONCILIATIONS Custody rules (CASS 6) (Deadline 1 June 2015) Current rules Investment firms are required to maintain records of custody assets in a manner which ensures their accuracy, and that they correspond with the custody assets they hold. Internal and external reconciliations should be carried out as often as necessary and as soon as practicable after the date of the reconciliation. Any discrepancies identified through the reconciliation process must be corrected promptly. Firms must also correct and make good any shortfall in custody assets where there are reasonable grounds for concluding that the firm is responsible for the shortfall. FCA has observed frequent occurrences of firms having poor record-keeping practices, and inadequate systems and controls to ensure the accuracy of records. FCA also consider that many firms do not understand their requirements in respect of custody asset recordkeeping, record checks and reconciliations. FCA are aware that firms using integrated systems to keep their custody records may not be able to carry out internal custody reconciliations, as it is not possible to extract two independent records from such a system. Consequently these firms will be required to carry out an internal custody record check. At least annually, firms must review the frequency of their custody record checks, physical asset reconciliations and external custody reconciliations (unless they are undertaken on a daily basis). FCA has indicated that, as best practice, it would expect firms to carry out daily external reconciliations if they hold assets electronically with a central securities depository and the third party is able to provide information on the firm s holdings on a daily basis. Currently CASS states that whenever possible reconciliations should be carried out by a person who is independent of the production or maintenance of the records being reconciled. The Policy Statement extends this to those responsible for checking the reconciliations as well. Firms carrying out custody records, physical asset reconciliations and external custody reconciliations less frequently than daily must introduce procedures to review and document why the frequency they choose is appropriate. Firms holding assets electronically with a central securities depository should consider whether they should carry out daily reconciliations (if the relevant information about holdings can be provided by the third party). Firms will need to consider the practical impact of the extension of the independence criteria to those who check reconciliations and how this will be implemented. 10 HOW THE NEW CLIENT MONEY RULES WILL AFFECT YOUR FIRM

15 Custody assets reconciliations HANDLING DISCREPANCIES AND SHORTFALLS IN CUSTODY ASSETS Custody rules (CASS 6) (Deadline 1 June 2015) Current rules Investment firms are required to maintain records of custody assets in a manner which ensures their accuracy, and that they correspond with the custody assets they hold. Internal and external reconciliations should be carried out as often as necessary and as soon as practicable after the date of the reconciliation. Any discrepancies identified through the reconciliation process must be corrected promptly. Firms must also correct and make good any shortfall in custody assets where there are reasonable grounds for concluding that the firm is responsible for the shortfall. FCA has observed frequent occurrences of firms having poor record-keeping practices, and inadequate systems and controls to ensure the accuracy of records. FCA also consider that many firms do not understand their requirements in respect of custody asset recordkeeping, record checks and reconciliations. FCA are aware that firms using integrated systems to keep their custody records may not be able to carry out internal custody reconciliations, as it is not possible to extract two independent records from such a system. Consequently these firms will be required to carry out an internal custody record check. Where a reconciliation has highlighted a shortfall in the safe custody assets held by the firm caused by a discrepancy, the firm must resolve the discrepancy immediately. If it is unable to do so, it must ensure client protection by segregating an equivalent amount of the firm s own assets/client money, so that this is held in such a way that it will be realised for clients benefit if the firm fails. If another person is responsible for the shortfall (or it is caused by timing differences between the firm s and a third party s accounting systems), the firm does not have to make good the deficit but may do so. Firms should take steps to resolve any such shortfalls as soon as possible. In certain circumstances firms may also need to consider whether to inform affected clients of the shortfall (for instance if the firm is informed by a third party of the loss of a custody asset). Firms will need to ensure that their policies and procedures meet the requirements to make good shortfalls. They should also check their own client money permissions and then ensure that any amounts they transfer for this purpose would only be available for clients benefit in the event of the firm s failure, and are clearly recorded. Firms which normally operate under the banking exemption or use title transfer collateral arrangements for monies received or held on behalf of clients will need to ensure that they have appropriate systems and controls in in place to hold client money in compliance with the client money rules. If a firm in these circumstances wishes to use its own money to cover shortfalls in custody assets, then it may need to repaper its agreements or other documentation with the client concerned to ensure that money may be held for the client s benefit as client money. Where a firm segregates its own money as client money to cover a custody shortfall, it will need to revisit the valuation each day to ensure it is still segregating the correct amount to cover the shortfall such assets will then form part of the custody assets included in the firm s next internal custody record check. HOW THE NEW CLIENT MONEY RULES WILL AFFECT YOUR FIRM 11

16 Custody asset recordkeeping, record checks and reconciliations Custody rules (CASS 6) (Deadline 1 June 2015) Current rules Existing systems and controls requirements require firms to document their policies and procedures for their custody reconciliations. FCA has observed frequent occurrences of firms having poor record-keeping practices, and inadequate systems and controls to ensure the accuracy of records. FCA also consider that many firms do not understand their requirements in respect of custody asset recordkeeping, record checks and reconciliations. FCA are aware that firms using integrated systems to keep their custody records may not be able to carry out internal custody reconciliations, as it is not possible to extract two independent records from such a system. Consequently these firms will be required to carry out an internal custody record check. Policy documents should set out the frequencies the firm will follow for its custody reconciliations and the rationale for these frequencies. They should also set out the procedures for the resolution of reconciliation discrepancies and the firm s procedures for escalating breaches and related issues to the firm s board and to the FCA where appropriate (this would include any materiality policies a firm adopts). Firms will be required to make and retain copies of each custody record check and/or reconciliation undertaken, each review conducted of these arrangements and their policy and procedures for complying with these requirements, including those around recordkeeping and reconciliations. Where a firm will be unable to comply with a specified requirement or where the firm materially fails to comply with a rule (ie there is a breach of the rule), a notification must be made to FCA. A materiality threshold applies to actual breaches, meaning not all breaches need to be notified to the FCA. What is material will depend on the circumstances and firms will need to consider this on a caseby-case basis. The requirement to establish and maintain written policies and procedures for some firms may need a significant resource commitment. The FCA did not provide additional guidance on whether or not a breach is material. Firms will need to consider the factors they will take into account when assessing whether a breach is considered material enough to warrant disclosure to FCA. 12 HOW THE NEW CLIENT MONEY RULES WILL AFFECT YOUR FIRM

17 CHANGES RELEVANT TO CASS 6 Physical share certificates 13 Registration of custody assets 13 Written custody agreements 14

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19 Physical share certificates Custody rules (CASS 6) (Effective from 1 July 2014) Current rules Firms which safeguard and administer assets must comply with the relevant safeguarding and administering rules. They require appropriate permissions, and must comply with the custody rules as required. No change merely a clarification, because some firms had questioned whether paper share certificates fall within the definition of designated investments or MiFID financial instruments (as legal title is recorded on the company register or in CREST). As the loss or destruction of share certificates could harm the client in certain circumstances, even though it might not automatically create a loss of title to shares, FCA reiterate that firms which are safekeeping physical share certificates do fall within the scope of the safeguarding. As a result, where a firm is also administering an asset for which it is holding a physical share certificate (eg processing corporate actions), it requires the appropriate permissions and must comply with the custody rules in respect of those assets. Registration of custody assets Custody rules (CASS 6) (Deadline 1 June 2015) Current rules In certain circumstances, a firm may currently register or record legal title to its own applicable assets in the same name as that in which legal title to a client s safe custody asset is registered. This poses the risk that when a firm fails, the client s safe custody assets may not be easily identifiable as separate from a firm s assets. Firms may record their own assets in the same name as any custody asset for no longer than is reasonably necessary: A) where doing so arises incidentally to the investment business the firm carries on for the account of a client, or to other steps taken by the firm to comply with the custody rules. For example: correcting dealing or transaction errors that relate to client positions; processing or allocating assets for bulk deals; maintaining a small balance of the firm s own assets (eg as a float to cover custody breaks); allowing clients to trade in fractional shares or units and when processing corporate actions; making good a shortfall in custody assets with a firm s own assets. B) where doing so arises only as a result of the law or market practice of a jurisdiction outside the UK. Firms should maintain documentation to demonstrate that they have considered each of the options available to them for the registration of their own applicable assets. Firms may not use the exceptions for any longer than is reasonably necessary and must also consider whether there are any means of avoiding using the exceptions. When placing assets in overseas jurisdictions, firms will continue to be obliged to disclose these circumstances in specific situations to certain clients. HOW THE NEW CLIENT MONEY RULES WILL AFFECT YOUR FIRM 13

20 Written custody agreements Custody rules (CASS 6) (Deadline 1 June 2015 for existing business) (Deadline 1 Dec 2014 for new business) Current rules There is no explicit requirement for investment firms to have written documentation in place to show the terms on which they place client assets with third parties (whether they are depositing them in the course of acting as their clients custodian, or by arranging custody of them on their clients behalf). The failure to adequately document the terms upon which assets are held creates uncertainty as to how assets should be treated in the event of a firm s insolvency and may lead to disputes over the responsibilities and obligations of the different parties involved. FCA are introducing an explicit requirement for firms to have written agreements in place whenever they place custody assets with a third party irrespective of whether that third party is an affiliate of the firm. Written agreements must: 1) set out the binding terms of the arrangement between the firm and the relevant third party; 2) be in force for the duration of that arrangement; and 3) clearly set out the custody service(s) that the third party is contracted to provide. Alternatively, the investment firm and the custodian could exchange their standard terms of business, or other documentation, as evidence of the terms on which the custodian services are provided. Firms will have to undertake a review of their terms of business agreements and establish whether these meet the revised requirements. If changes are required, a repapering exercise will be required with the custody service providers. If firms rely on standard terms of business or other documentation for this purpose, they must ensure that these meet all the requirements of PS14/09. Care must also be taken to ensure clarity as to which document takes precedence if there is a conflict. Any changes to documentation will need to be reflected by firms in their CASS resolution packs. 14 HOW THE NEW CLIENT MONEY RULES WILL AFFECT YOUR FIRM

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