Q: Do I enter monetary figures in the CMAR in full or in thousands?
A: Monetary figures should be given in thousands (000’s). For example £52,000,000 (fifty-two million pounds) should be recorded as 52,000. Please round up monetary figures to the nearest thousand and record zero amounts as 0.
Q: I have used the xml submission method to upload my CMAR and I get a technical error when I try to open the draft CMAR.
A: In line with other returns on Gabriel, firms should not use characters which cause issues in XML eg é (acute) ã (tilde) etc. Firms should remove all international language accent marks from their xml before uploading to Gabriel to avoid potential problems.
Q: There appears to be a validation formula problem in data element 20A – what should I do?
A: In the CMAR for the return periods of October 2011 until February 2012 an error developed in the validation rule for data element 20A. It should have been 19A - 14A, rather than 14A - 19A.
This has now been resolved. The validation rule has been corrected to be 19A – 14A.
Firms’ CMAR submissions for the March 2012 return period onwards now have the correct validation rule. (This is the March 2012 return that firms must submit within 15 business days of the end of the reporting period, ie by 24 April 2012.)
Firms should not resubmit previous CMARs (October 2011 to February 2012) to correct this validation rule error.
Q: What should a firm report in the data fields 26 A, B , and C?
A: In this data element, firms should report their custody breaks.
Firms should only complete CMAR data element 26A with number of safe custody assets for the <[hidden] style="display: none; ">no more than 30 days period if this data is readily available to them. Firms for whom the data is not readily available should enter a ‘zero’. Firms should provide data for CMAR elements 26B and C (to ensure that the form validates, if firms have nil returns for 26B and C, a ‘zero’ must be entered).
Q: Data elements 6A, 7A, 31A, 32A, 33A and 34A appear to be mandatory – what do I do if my firm did not hold client money/client assets [as applicable]?
A: These data elements are mandatory for all firms, irrespective of whether they declare that they held client money or custody assets during the relevant reporting period.
This is to ensure that firms consider carefully whether they held client money or custody assets. A response to these questions will be necessary, to ensure that the CMAR validates and can be submitted. If a firm is content that client money or custody assets were not held as applicable, it should fill out the relevant data elements of the CMAR in the following manner:
Element 6A: (Does the firm operate the alternative approach?) - mandatory Yes/No answer. If the firm did not hold client money (as per 3a), it should answer ‘No’ for this element.
Element 7A: (Has the alternative approach been signed off by the firm's auditors (as detailed in CASS 7.4.14G - 7.4.16G)?) - mandatory Yes/No/NA answer. NA is appropriate if the firm did not hold client money.
Element 31A: (Has the firm complied with the requirements in CASS 6.5.1R, 6.5.2R and 6.5.6 R?) - mandatory Yes/No answer. If the firm did not hold custody assets, the firm should answer 'Yes'.
Element 32A: (Following reconciliation, is the firm unable, in any material respect, to comply with 6.5.10 R?) - mandatory Yes/No answer. If the firm did not hold custody assets, the firm should respond with 'No'.
Element 33A: (Has the firm complied with the requirements in CASS 7.6.1R, 7.6.2R and 7.6.9R?) - mandatory Yes/No answer. If the firm did not hold client money, the firm should answer ‘Yes’.
Element 34A: (Following reconciliation is the firm unable, in any material respect, to comply with the requirements in CASS 7.6.13R to 7.6.15R?) - mandatory Yes/No answer. If the firm did not hold client money, the firm should respond with ‘No’.