CMAR: How to Prepare and File the Client Money and Asset Return

    In short

    The CMAR, or Client Money and Asset Return, is the monthly return in which CASS medium and CASS large investment firms report their client money and safe custody assets to the FCA. Under SUP 16.14.3R it is due within 15 business days of each month end. It has nine sections, from balances and reconciliations to breaches and outsourcing, and the person given CASS oversight completes and submits it.

    Key takeaways

    • The CMAR rules in SUP 16.14 apply to CASS large firms and CASS medium firms; CASS small firms do not file a CMAR.
    • A completed CMAR must reach the FCA within 15 business days of the end of each month, submitted electronically through the FCA's systems.
    • The return has nine sections: firm information, balances, segregation of client money, requirement and resource, client money reconciliations, segregation of custody assets, custody checks, record keeping and breaches, and outsourcing.
    • Client money figures come from the firm's own records rather than bank statements, and foreign currency is converted to sterling at the previous day's closing spot rate.
    • Completing and submitting the CMAR is part of the CASS oversight function that CASS 1A.3.1AR requires a medium or large firm to give to a single director or senior manager.
    • Answering the breach questions in the CMAR does not replace the duty to tell the FCA about a notifiable breach without delay when it happens.

    What the CMAR is

    The Client Money and Asset Return, known as the CMAR, is a regulatory return: a standard form a firm completes and sends to the FCA at fixed intervals. It gives the FCA a monthly picture of how much client money and how many safe custody assets a firm holds, where they are held, how well the firm's checks are working and whether anything has gone wrong. Client money is cash a firm holds for its clients. Safe custody assets are investments, such as shares, bonds and fund units, that a firm holds or controls for clients. The FCA's own pages use both 'Client Money and Asset Return' and 'Client Money and Assets Return' for the same form.

    The CMAR belongs to the investment firm rules: the custody rules in CASS 6 and the client money rules in CASS 7. Payment and e-money firms that safeguard customer funds under CASS 15 file a different return, which our guide to CMAR and REP027 explains. The FCA says the CMAR is also meant to help the firm's board and its senior manager responsible for CASS understand the firm's own position.

    Who has to file a CMAR

    SUP 16.14.1R applies the CMAR to CASS large firms and CASS medium firms. A firm's CASS type is set each year under CASS 1A.2 from the highest amount of client money, or the highest value of safe custody assets, it held in the previous calendar year. Our guide to CASS firm classification and oversight explains the calculation in full.

    Where a firm's CASS type changes, SUP 16.14.3R(3) says it does not need to submit a CMAR for the month in which the change takes effect, unless it was already required to file before the change. A firm moving from small to medium should therefore plan for its first full return from the month after the change.

    CASS firm typeClient money (highest in previous year)Safe custody assets (highest in previous year)Files a CMAR?
    CASS large firmMore than £1 billionMore than £100 billionYes, monthly
    CASS medium firm£1 million to £1 billion£10 million to £100 billionYes, monthly
    CASS small firmLess than £1 millionLess than £10 millionNo

    Frequency and deadline

    SUP 16.14.3R(1) requires a completed CMAR within 15 business days of the end of each month. The FCA's guidance notes say the reporting period is the calendar month, whether or not any particular day in it is a business day. Data can be entered from the first day of the following month, and the firm's principal user of the FCA's reporting system receives reminder emails 8 days and 3 days before the deadline. SUP 16.14.6R requires electronic submission.

    A report that is not complete by its due date attracts an administrative fee of £100 under SUP 16.3.14R, and late or non-compliant submission can also lead to disciplinary action. Fifteen business days leaves little room once the month-end reconciliations, custody checks and reviews are counted, so most firms fix an internal timetable that finishes several days early. The table shows the due dates for the next four returns, counting business days in England and Wales.

    Reporting monthMonth endCMAR due (15th business day)
    September 2026Wednesday 30 September 2026Wednesday 21 October 2026
    October 2026Saturday 31 October 2026Friday 20 November 2026
    November 2026Monday 30 November 2026Monday 21 December 2026
    December 2026Thursday 31 December 2026Friday 22 January 2027

    The nine sections of the CMAR

    The form is set out in SUP 16 Annex 29R and the FCA's guidance notes for completing it are in SUP 16 Annex 29AR. The nine sections follow the life of client money and custody assets: who the firm is and what it holds, how much, where, whether the books balance, whether the checks were done and what they found, whether records and notifications were kept up, and who else does the work.

    Sections 4, 5 and 7 are the ones that depend most on daily operations, because they report the outcome of reconciliations rather than balances. A firm whose reconciliations are late or poorly evidenced during the month will find these sections slow to complete and hard to defend.

    SectionWhat it asks for
    1. Firm informationCASS auditor, whether the firm held client money or custody assets, use of the alternative approach and auditor assurance given to the FCA, clients and balances by business type
    2. BalancesHighest and lowest client money balance, and highest and lowest custody asset value, during the month
    3. Segregation of client moneyEach bank or other institution holding client money, the balance, its country and whether it is a group company
    4. Client money requirement and resourceWhat the firm owed clients, what it held, the excess or shortfall, and adjustments after the internal reconciliation
    5. Client money reconciliationsHow often internal and external reconciliations were done, and unresolved items by age
    6. Segregation of safe custody assetsHow assets are registered and held, each custodian, number of stock lines and value
    7. Custody record checks and reconciliationsUnresolved custody items by age, and the type and frequency of each check
    8. Record keeping and breachesClient bank and transaction accounts opened and closed, how many are covered by acknowledgement letters, and whether notifiable breaches arose
    9. Outsourcing and offshoringWho performs client money or custody work for the firm, where, and planned changes

    Where the figures come from

    The guidance notes are specific. Client money balances should come from the firm's internal records, not from the figures in bank or third-party statements, and the month-end balances are taken from the internal reconciliation performed on the first business day after the month ends. The highest and lowest figures in section 2 are the highest and lowest amounts held at any point in the month, taken from internal records, not simply the month-end figure. Custody asset values in section 1 are as at the last business day of the month, and the FCA does not prescribe how or how often custody assets must be valued.

    Everything is reported in sterling. Amounts in other currencies are converted at the previous day's closing spot exchange rate. In section 5, only client money items unresolved for six calendar days or more are reported, and differences caused solely by timing differences between the firm's and a third party's accounting systems are left out. Unresolved custody items are reported in bands of 30 to 59, 60 to 89 and 90 or more days.

    Worked example: a CASS medium firm's September return

    A discretionary wealth manager is a CASS medium firm. It holds client money in five client bank accounts across two banks, one of them opened in September, and custody assets through one custodian. For September 2026 it must file by Wednesday 21 October 2026. Its daily internal reconciliations show client money ranged from £41,180,000.00 to £48,640,000.00 during the month. The reconciliation performed on Thursday 1 October gives the month-end requirement and resource below. One of its accounts holds US dollars, converted at the previous day's closing spot rate.

    Two items appear in the reconciliation sections. A £3,400.00 bank charge wrongly debited to a client bank account has been open for eight days, so it is reported in the client money ageing table. A dividend difference on one stock line at the custodian has been open for 34 days, so it falls in the 30 to 59 day band for custody. It holds a countersigned acknowledgement letter for all five accounts, including the new one, so no explanation of a difference is needed. No notifiable breach arose, so the breach questions are answered No.

    CMAR lineFigure
    Section 2: highest client money in the month£48,640,000.00
    Section 2: lowest client money in the month£41,180,000.00
    Section 4: client money requirement at month end£44,912,300.00
    Section 4: client money resource at month end£44,962,300.00
    Section 4: excess (withdrawn on 1 October)£50,000.00
    Section 5: unresolved client money items, 6 to 29 days1 item, £3,400.00
    Section 7: unresolved custody items, 30 to 59 days1 item
    Section 8: client bank accounts at month end / covered by letters5 / 5
    Section 8: notifiable breaches arose in the monthNo

    The breach and acknowledgement letter questions

    Section 8 asks whether any of the circumstances in CASS 6.6.57R or CASS 7.15.33R arose in the month and whether the firm met the notification requirements. Those rules list the events the FCA must be told about in writing without delay, such as materially inaccurate records, an uncovered shortfall or a reconciliation the firm could not perform. The guidance notes say a firm should answer Yes if it failed to comply with any of those rules in the month, even if it was back in compliance by month end.

    The guidance also says that filing the CMAR on time does not discharge the duty to notify without delay. A firm that leaves a notifiable event for the next CMAR has two problems, not one. Our guide to CASS breach reporting sets out each notification and how to make it. In the same section, any difference between the number of client bank accounts and the number covered by acknowledgement letters needs a brief explanation, because CASS 7.18.2R does not allow client money to be held in an account until its countersigned letter has been received.

    Common CMAR errors and the control for each

    Most errors in a CMAR come from preparing it as a month-end exercise rather than from the records the firm already keeps each day. The table lists the errors that follow most directly from the way the guidance notes are written, with the control that prevents each.

    None of these needs a separate month-end exercise if the daily records already capture the right data: the balance series, the exchange rate used, the cause of each reconciliation item and the breach log. The return then becomes a summary of work already done and reviewed.

    ErrorWhy it is wrongControl
    Reporting bank statement balancesThe guidance requires internal record valuesTake figures from the first business day's internal reconciliation
    Highest balance taken from month endSection 2 asks for the highest point in the monthKeep a daily balance series from each internal reconciliation
    Wrong exchange rateThe previous day's closing spot rate appliesStore the rate used in each daily reconciliation
    Timing differences reported as unresolved itemsItems caused solely by timing differences are excludedClassify every reconciliation item by cause when it appears
    Breach answered No because it was fixed by month endYes applies if the rule was breached at any pointReconcile section 8 to the breach register before sign-off
    Unbreakable deposits not shown separatelySUP 16.14.7R requires 31 to 60 and 61 to 95 day amounts to be reported apartFlag notice accounts in the bank account register
    Late submission£100 administrative fee and possible further actionFix an internal deadline several business days early

    Review, sign-off and the audit

    CASS 1A.3.1AR requires a CASS medium or large firm to give a single director or senior manager the function of overseeing its CASS systems and controls, reporting to the governing body and completing and submitting the CMAR. The FCA notes that even where others prepare the form, its senior manager responsible for CASS remains responsible for its being complete, accurate and on time. A sensible process has the return prepared by one person, reviewed by another who did not prepare it, and signed off by the oversight holder against the month's reconciliation records.

    The CMAR and the annual CASS audit cover the same ground, and the auditor is named in section 1. A return that does not agree with the records the auditor later tests, or that answered No to breaches the auditor finds, is a finding in its own right. Keeping each month's working papers with the return that used them makes both easier.

    Safeheld reconciles client money every day for regulated firms, works every difference to its cause and keeps the record auditors ask for, and is extending that work to CASS 6 and CASS 7 reporting. If your firm files a CMAR, talk to us about CMAR reporting.

    Frequently asked questions

    What is a CMAR?

    The Client Money and Asset Return: a monthly return in which CASS medium and large investment firms report their client money, safe custody assets, reconciliations and breaches to the FCA.

    Who has to submit a CMAR?

    CASS large firms and CASS medium firms under SUP 16.14.1R, meaning firms that held at least £1 million of client money or at least £10 million of safe custody assets at their peak in the previous calendar year.

    When is the CMAR due?

    Within 15 business days of the end of each month under SUP 16.14.3R. The return for September 2026 is due by 21 October 2026.

    Do CASS small firms submit a CMAR?

    No. SUP 16.14 applies only to CASS large and CASS medium firms.

    What exchange rate is used in the CMAR?

    Amounts in other currencies are converted to sterling at the previous day's closing spot exchange rate, according to the FCA's guidance notes.

    Does reporting a breach in the CMAR count as notifying the FCA?

    No. Notifiable breaches under CASS 6.6.57R and CASS 7.15.33R must be notified in writing without delay; the CMAR only records whether they arose and were notified.

    What happens if a CMAR is submitted late?

    The firm must pay an administrative fee of £100 under SUP 16.3.14R, and late or non-compliant submission can lead to further disciplinary action.

    References

    About Safeheld

    Safeheld reconciles client money every day, resolves every difference and prepares every regulatory return for sign-off, for regulated firms in the United States, the United Kingdom, the European Union, Canada, Australia, Singapore and Hong Kong. To discuss your operations, contact us at safeheld.com/contact.

    This article is for general information and does not constitute legal or regulatory advice.

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