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DVP exemption - CASS Provision: Difference between revisions
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The DVP exemption allows a firm a waiver from the full rigours of the CASS safe custody and [[client money]] rules or the client money rules for money or assets delivered to the firm when settling a [[delivery versus payment]] transaction. As long as the transaction takes place through a [[commercial settlement system]], is intended to settle within one business day of the client's payment or delivery, and actually does settle within the “[[DVP window]]” (a period from the intended settlement date to the close of business on the third business day thereafter) | The DVP exemption allows a firm a waiver from the full rigours of the CASS safe custody and [[client money]] rules or the client money rules for money or assets delivered to the firm when settling a [[delivery versus payment]] transaction. As long as the transaction takes place through a [[commercial settlement system]], is intended to settle within one business day of the client's payment or delivery, and actually does settle within the “[[DVP window]]” (a period from the intended settlement date to the close of business on the third business day thereafter). | ||
===The changes wrought by [[PS14/9]]=== | |||
The DVP exemption was tightened up by the {{tag|FCA}} in the great CASS overhaul following its market position paper [[PS14/9]] because the FCA was concerned about a lack of clarity/creative looseness as to: | |||
*what a "[[commercial settlement system]]" is in practice, as it was not defined. Reaction: [[Commercial settlement system|define it]]. | |||
*when the [[DVP window|DvP window]] actually starts, so it was "stretched" beyond what was intended - in some cases for months. | |||
The DVP exemption | The amended rules provide that: | ||
*in respect of a client's purchase the [[DVP window]] starts from the date of the client's fulfillment of its payment obligation to the firm (provided the firm intends for the asset in question to be due to the client within one business day following fulfillment) and closes when the transaction settles (or, failing that on the third business day following fulfillment); | |||
*in respect of a client's sale, the DvP window starts from the date of fulfillment of dlievery and closes when the transaction settles (or, failing that on the third business day following fulfillment); | |||
===[[Banking exemption]]=== | |||
If your institution counts as an {{fcaprov|approved bank}} consider whether this amounts to a whole hill of beans anyway because you have an exemption from the requirement to hold client money in relation to {{fcaprov|designated investment business}} in the first place: CASS {{cassprov|7.10.16}} R and {{cassprov|7.10.18}} G. | |||
{{cassanatomy}} | |||
{{seealso}} | |||
*{{cassprov|7.11.14}} - [[client money]] DVP exemption. | |||
*{{cassprov|6.1.12}} - [[custody]] DVP exemption. | |||