Client Assets

Bovill has a wealth of experience in working and complying with the rules of the FCA Client Assets Sourcebook.

We have a mature team with experience of all aspects of client assets and money (CASS) including carrying out section 166 project work, audit support, remedial projects and CASS training. We won’t offer you a generic product, we’ll work hard to find a solution that fits your business.

CASS processes and controls

Working 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

Creating or updating your CASS risk and control framework by carrying out a review of your business against the CASS rules. Working together with your team we can evaluate the CASS risks your business faces and document the controls in place to address them.

CASS policies and procedures

We can draft these from scratch or update your existing policies and procedures. We can take the lead and do all the drafting for you, or we can provide quality assurance input to the drafts you produce.

Governance and oversight

Assessing whether your CASS governance and oversight is adequate, including review of management information, breach escalation, committee terms of reference and the responsibilities of the CF10a.

CASS audit preparation and assistance

Helping you prepare before the auditor arrives, advising you on contestable findings before their report is finalised or assisting you with remedial work.

CASS healthchecks

We can help you assess the adequacy of your CASS controls, whether by carrying out a high-level review of your CASS arrangements or a full bottom-up review of processes. This can lead to proportionate and effective recommendations for improvements to your processes.

CASS training

One-to-one training for senior staff or group-style training for the whole business, or 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.

CASS RP preparation and testing

Creating a CASS RP or testing your current one is fit for purpose. This can include a surprise ‘mock FCA’ request to test if your team can meet all the information deadlines.

CASS s166

Acting as skilled person when the FCA issues you with a s166 notice or as your trusted adviser and support during a s166 review. We can also perform mock s166 reviews if you have a CASS issue you’d like an independent opinion on.

Total capture reviews

Looking at all the products and services offered by your business to ensure that you have captured your total client assets population. Obtaining this assurance gives you comfort that you’re segregating and safeguarding the right assets and applying any exemptions correctly.

Specialist advice

  • 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!)
Additional resource

  • Compliance monitoring
  • Secondments
  • CMAR preparation
  • Due diligence of banks and custodians

Bovill client assets (CASS) Experience

Our UK client assets team is experienced and technically able, and our standards are high. We work with a wide variety of businesses – pretty much every type of business that Bovill as a firm deals with – including investment and wealth managers, stockbrokers, global banks, private banks, fund managers, depositaries, peer to peer lenders and everything in-between.

Our people come from backgrounds in law, in-house compliance, the FCA and Big Four consultancies – so we can interpret the rules from many different angles. We all bring varied experience and we can share with you what we see from a CASS point of view in the financial services industry and give insights into industry best practice
in your area.

For more information on how Bovill can help with your CASS requirements, please get in touch.

Download the client assetsBovill CASS offering in PDF

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