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Client Money: Annual Classification & Notification

Once a year, firms that have permissions to hold client money and/or safe custody assets from investment business are required to determine their CASS classification.

Client Money Classification Annual Requirement

At the start of each year, and no later than 15 business days from 31 December of the previous year, CASS firms must notify the regulator of their CASS firm type classification.

All CASS Small firms and firms that have relevant permissions to hold client money and/or safe custody assets (but that reported zero balances in the previous year) will also be sent a CASS classification questionnaire from the FCA.

These usually get distributed via email each December to either the CF10a or SMF18. (Should a firm not be required to have either, then the Firm’s Principal User within Gabriel will be contacted by the FCA).

The CASS questionnaire for these firms will ask you to confirm your highest client money and/or safe custody assets holdings during the last calendar year to determine your classification for the coming calendar year.

Should your firm have held zero balances, then the regulator will require you to confirm the highest projected holdings for the coming calendar year.

CASS Medium and CASS Large Firms will not usually have to report on any balances at this time however, as they will have submitted the Client Money and Asset Returns (CMARs) during the previous calendar year.

>> See more on CASS Firm Types - CASS Large Firms vs CASS Medium Firms <<

Client Money Support & Compliance Assistance

Compound Growth can assist firms of all sizes to ensure they have the necessary procedures in place to remain compliant with the regulator’s rules pertaining to client money and client assets as set out in the CASS Sourcebook.

In particular we can support your firm in establishing suitable accounting systems as well as developing client money policies in line with industry best practice and the FCA’s guidance.

If you would like to discuss client money or client assets further, please feel free to contact us or email

Client Money Segregation


What is Client Money?

Client Money News