Margin account redaction is the removal of personal data from a credit ledger secured on investments. Two client-asset regimes usually apply at once: CASS 6 governs custody of the securities used as collateral, including the records, accounts and reconciliations in CASS 6.6, and CASS 7 governs client money held alongside them. The terms of the facility — margin levels, call rights and close-out — belong in the written client agreement required by FCA COBS 8A. Where the facility is a regulated credit agreement rather than an exempt one, the FCA's CONC rules apply on top. SYSC 9.1.1R requires the whole record to be orderly. anonym.plus marks each identifier on your device, so the exposure figures stay while the borrower goes.
When this applies
A credit ledger pairs the borrower's identity with loan balances, collateral haircuts and margin-call history. A risk committee, a stress test or a model validation needs the exposure profile, not the borrower. You trim the identity before the ledger circulates; the firm's own record stays orderly for SYSC 9.1.1R.
How anonym.plus handles it
- Open the ledger in anonym.plus on your device.
- Local OCR reads scanned statement and margin-call pages.
- The tool flags name, NI number and account numbers.
- Keep the loan balances, collateral values and call dates.
- Mask account numbers and swap or black out the rest.
- Save the clean copy locally.
What you need to provide
- The credit ledger (PDF, DOCX, CSV, or scan).
- An operator (Mask suits account numbers).
- Optional batch for many statement pages, up to 20 files per run.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | borrower D. Frost → [BORROWER] |
| Identifiers | UK_NINO | QQ 41 29 08 B → [NINO] |
| Financial | UK_BANK_NUMBER | margin acct 0091 → ****0091 |
| Money | MONEY | debit £210,000 → [BALANCE] |
| Dates | DATE_TIME | call date 2025 → [DATE] |
| Contact | PHONE_NUMBER | +44 131 496 4410 → [PHONE] |
Compliance achieved
- Securities pledged as collateral sit under CASS 6, with records, accounts and reconciliations governed by CASS 6.6; cash held alongside them sits under CASS 7. Both regimes turn on the records, which redaction of a shared copy leaves intact.
- Margin levels, call rights and close-out powers belong in the written client agreement required by FCA COBS 8A for MiFID business — a redacted extract is enough for most reviews of those terms.
- Where the facility is a regulated credit agreement rather than an exempt one, the FCA's CONC rules apply on top; whether they do is a legal question the tool does not answer for you.
- FCA SYSC 9.1.1R requires records orderly enough for the FCA to monitor the business, and UK GDPR Art. 5(1)(c) limits what a risk reviewer needs to receive.
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Limitations & cautions
A large debit paired with a dated margin call points to one borrower with every name removed, and concentrated collateral is a fingerprint. The tool flags named items, not exposure patterns, and it does not classify the facility for CONC purposes. Review the entries before you circulate.
Frequently asked questions
Whose data should I redact in a margin ledger?
The borrower's identity, National Insurance number and linked account numbers. The balances, collateral values and call dates a risk review actually uses can stay, and the CASS 6.6 reconciliation trail is unaffected.
Can the loan figures stay?
Yes. Allow-list the balances, haircuts and dates. Only personal identifiers are masked or removed, so the exposure profile survives for stress testing.
Is the ledger uploaded?
No. Processing runs locally, so credit and collateral data stays on your machine.