In October 2017, ASIC released Information Sheet 226 Complying with the ASIC Client Money Reporting Rules (Info Sheet 226) which included fields pertaining to client monies held with brokers as per the ASIC reconciliation template.
This caused confusion for many in the OTC derivatives industry and prompted some to seek clarification regarding the intention behind the included data fields.
This past week, ASIC sent a questionnaire to licensees requesting information in relation to the performance of ASIC’s function of monitoring and promoting consumer protection in relation to the Australian financial system as set out in s12A (2) of the ASIC Act 2001. The questionnaire contains ten questions including a combination of yes or no answers and short responses, which must be completed and returned to ASIC by 12 February 2018.
The questionnaire covers all aspects of the licensee’s businesses including management’s understanding of Client Money Reporting Rules, the implementation of monitoring programs regarding the licensee’s compliance with Client Money Reforms and any training or systems which the licensee is planning to implement in order to comply with the client money reforms and new requirements outlined in Info Sheet 226.
Sarah works with the Compliance Team with a particular focus on compliance and legal services. Sarah also works with the Legal Team providing ongoing assistance in drafting and reviewing documentation as well as legal research. Sarah assists clients with AFSL and ACL applications, variations and also assists in the implementation of compliance reviews. She provides ongoing compliance support in the form of compliance program implementation and reviews.