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CMAR Questions & Sections

We have previously spoken about CMAR  (the Client Money and Assets Reporting return) that medium and large CASS firms must submit on a monthly basis in GABRIEL. However, the following provides additional details on the specific questions asked within the CMAR return.

CMAR Sections

The questions that are asked within the CMAR are detailed within the Annex to the FCA’s Supervision Handbook (SUP). There are a number of CMAR questions, which are grouped into nine separate sections, these being:

CMAR Questions: Mandatory information

Much of the CMAR Reporting form is mandatory. For example, all reporting firms will have to provide the highest and lowest client money balances and value of safe custody assets held during the reporting period.

In addition, all those holding client money during the reporting period will have to provide the frequency of internal and external client money reconciliations plus provide details of any unresolved client money issues.

Furthermore all firms are required to inform of any notifiable CASS breaches and whether they have complied with the notification requirements.

Exemptions on CMAR Questions

It should be noted however that not all of the CMAR sections have to be completed by all firms. A number of sections are dependent upon whether a firm has actually held client money within the period. In addition the particular circumstances of the firm will determine whether other sections need completing. For example, section 9 on Outsourcing and Offshoring should only be completed by firms that outsource and/or offshore client money and/or client asset operations.

Related Reading: See also >> Client Money & Assets Reporting (CMAR)

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

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