COBS 15.9 COBS 15.9 Reconciliation
An Authorised Person must:(a) at least every calendar month, reconcile its records of Client Accounts held with Third-Party Agents with monthly statements received from those Third-Party Agents;(b) at least every six months, count all Safe Custody Investments physically held by the Authorised Person, or its Nominee Company, and reconcile the result of that count to the records of the Authorised Person; and(c) at least every six months, reconcile individual Client ledger balances with the Authorised Person's records of Safe Custody Investment balances held in Client Accounts.
An Authorised Person must ensure that the process of reconciliation does not give rise to a conflict of interest.
An Authorised Person must maintain a clear separation of duties to ensure that an employee with responsibility for operating Client Accounts, or an employee that has authority over Safe Custody Investments, must not perform the reconciliations under Rule 15.9.1.
COBS 15.9.4(a) Reconciliation performed in accordance with Rule 15.9.1 must be reviewed by a member of the Authorised Person who has adequate seniority.(b) The individual referred to in Rule 15.9.4(a) must provide a written statement confirming that the reconciliation has been undertaken in accordance with the requirements of this section.
The Authorised Person must notify the Regulator where there have been material discrepancies with the reconciliation which have not been rectified.
A material discrepancy includes discrepancies which have the cumulative effect of being material, such as longstanding discrepancies.