The FCA’s client money and assets rules – known as CASS – have remained a focus for the regulator since the financial crisis of 2008. Intended to protect client money and custody assets, the rules make sure they are adequately ring-fenced in the event of a firm’s failure. Client money needs to be kept separate from firm money, and client assets must be adequately registered.
We can help you manage client money and assets
We have a wealth of experience in complying with the rules of the FCA Client Assets Sourcebook. Our team has worked on all aspects of CASS including carrying out section 166 project work, audit support, remedial projects and CASS training. We won’t offer you a generic service, we’ll work hard to find a solution that fits your business.
CASS processes and controls
We can work with you to design or revise your CASS processes and controls. This could involve refining your reconciliation processes, record-keeping mechanisms or designing a more efficient CMAR process.
CASS risk and control framework
Working alongside your team, we will check your business against the CASS rules, evaluate the CASS risks you face and document the controls in place to address them.
CASS policies and procedures
We can take the lead and draft these from scratch or update your existing policies and procedures. We can also provide quality assurance input to the drafts you produce.
Governance and oversight
We can assess whether your CASS governance and oversight is adequate. This includes the review of management information, breach escalation, committee terms of reference and the responsibilities under SMCR of what was the CF10a.
CASS audit preparation and assistance
If you expect a CASS audit, we can help you prepare before the auditor arrives, advise you on contestable findings before their report is finalised or assist you with remedial work.
CASS health checks
Whether by carrying out a high-level review of your CASS arrangements or a full bottom-up review of processes, our health checks will assess the adequacy of your CASS controls, leading to proportionate and effective recommendations for improvements where needed.
We provide one-to-one training for senior staff or group-style training for the whole business, and anything in-between. Our CASS training sessions are always specific to your business, communicating how CASS applies to your firm and the risks you face.
Total capture reviews
By looking at all the products and services your business offers, we can provide assurance that you have captured your total client assets population. This will give you comfort that you’re segregating and safeguarding the right assets and applying any exemptions correctly.
CASS Resolution Pack preparation and testing
Whether you need us to create a CASS RP from scratch or check that your current one is fit for purpose, we’re here to help. This can include organising a surprise ‘mock FCA’ request to test if your team can meet all the information deadlines.
If the FCA issues you with a s166 notice, we can act as skilled person or as your trusted adviser to support you during the s166 review. We can also perform mock s166 reviews if you have a CASS issue on which you’d like an independent opinion.
We provide additional specialist CASS compliance advice and resources
We help clients with a wide range of issues, including:
- Prudent segregation vs pre-funding
- Creation of internal records
- Use of the internal system evaluation method for internal custody record checks
- Tricky technical queries (we love a hard question!)
Need additional resource? We can help you with:
- Compliance monitoring
- CMAR preparation
- Due diligence of banks and custodians