Reconciliation discrepancies - CASS Provision

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CASS Anatomy™


7.15.29 Reconciliation discrepancies: When a discrepancy arises between a firm's client money resource and its client money requirement identified by a firm's internal client money reconciliations, the firm must determine the reason for the discrepancy and, subject to CASS 7.15.29AR, ensure that:

(1) any shortfall is paid into a client bank account by the close of business on the day that the reconciliation is performed; or
(2) any excess is withdrawn from a client bank account within the same time period.



IMPORTANT: CASS changed quite a bit after MiFID II. This resource therefore may well be out of date, even if it was accurate once, which it might not have been. This is an article about the FCA’s custody and client money rules — client assets — and is fondly known by its chapter in the FCA SourcebookTable of Contents | 1 | 1A | 3 | 5 | 6 (custody rules) | 7 (client money rules) | 7A | 8 | 9 (PBDA) | 10

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The equivalent to the shortfall provision under CASS 6.6.54, this relates to reconciliation discrepancies in the client money record.

When a discrepancy arises between the amount of client money a firm holds and the amount it thinks it is meant to be holding it must figure out why and, subject to CASS 7.15.29AR, make sure that it tops up any shortfall into a client bank, or withdraws any excess.