CMAR: CLIENT MONEY & ASSET RETURNS
As the FSA targets its sights on the protection of client money and assets, medium and large firms are required to report monthly on Client Money and Asset Return (CMAR).
TCC provides support with filing GABRIEL and online notifications and as part of this service we are happy to assist you with CMAR reporting.
This new reporting regime is being implemented due to a number of failings within large financial companies in the past few years. The protection of client assets may seem an onerous addition to your monthly reports and yet is vital if you want to help prevent being targeted for inspection.
Associated risks:
- Insufficient resource and oversight
- Incorrect or absent trust documentation
- Inadequate records and reconciliations
- Inadequate systems and process changes
- Overreliance on group or third-parties
- Inappropriate conversion of client rights
Our CMAR reporting service will be relevant to you if you are one of the circa 400 medium and large companies who have to file a monthly report. Furthermore if you are a CF10a (relevant to client assets) you will benefit from this service.
Client Assets
As well as TCC's CMAR reporting service, with regard to client assets TCC can provide a full review of processes to ensure your procedures are robust enough to handle scrutiny. A review may cover (but is not limited to):
The management structure and governance arrangements
Responsibilities and reporting lines within the area, in particular whether these are clear and appropriate
The firm’s compliance arrangements, including the scope of compliance activities, the authority of the compliance function and the appropriateness of compliance resources
The appropriateness of the risk management arrangements, including the process for identifying risk, its risk controls and the monitoring of risk
The appropriateness of the management information, in particular its scope, distribution and the arrangements for analysis
The recruitment procedures, in particular, whether these are sufficient to ensure the fitness and propriety of the firm’s employees and agents
The firm’s training and competence arrangements, in particular, the arrangements in place to ensure that staff maintain their competence and are appropriately supervised/monitored
The arrangement made to monitor business
The extent to which the firm has defined procedures and standards covering its activities and whether these have been designed to ensure compliance with the regulatory requirements applicable to the task. This will include:
Mechanisms for marketing the firms services
Client classification
Ensuring the suitability of investment decisions
Disclosure to customers
New customer processes
Administration
The appropriateness of the data security and business continuity arrangements
The robustness of the record keeping arrangements
Following completion of the review, TCC will produce a detailed report analysing any gaps in current arrangements and including recommendations for any areas requiring redress.
To discuss further, please call us on 020 3008 6020 or email info@theconsultingconsortium.com
