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How to Meet PS14/9 Requirements

PS14/9 mandates that firms must put in place systems and controls that are necessary to meet their obligations to maintain their records and accounts, in a way that ensures their accuracy and in particular their correspondence to safe custody assets and client money held for clients.

The FCA expect better recordkeeping and record retention to prove controls are in place, operating effectively and that clients are indeed protected.

CASS 6 - Custody Asset Reconciliations

Therefore from today, to meet CASS 6 requirements a firm must:

  • Maintain client specific safe custody asset records;
  • Undertake an internal custody check at least once a month; and
  • Undertake an external custody reconciliation at least monthly, but daily where client assets are held electronically with a central securities depositary.

CASS 7 – Client Money Reconciliations

For CASS 7, firms must be able to:

  • Determine at any time, without delay the total client money it should be holding for each of its clients;
  • Reconcile on a daily basis its internal records and accounts of the amount of client money that the firm holds for each client, with its internal records and accounts of the client money the firm holds in client bank accounts;
  • Segregate client money immediately; and
  • Undertake an external reconciliation between a firm's internal records and accounts and those of any third party who hold client money.

How to ensure PS14/9 compliance

From performing Internal and External Reconciliations, to automating the CMAR and CASS Resolution Pack, our free-to-view paper - How to Meet PS14/9 Requirements – explains how to implement a robust, automated financial control regime to ensure PS14/9 compliance for both custody assets and client money.