CLIENT ASSETS AND MONEY
The FCA's regulations governing client money and assets, commonly referred to as CASS, have been a focal point for the regulator since the aftermath of the 2008 financial crisis. Designed to safeguard client money and custody assets, these rules ensure proper ring-fencing to protect them in the event of a firm's insolvency. Specifically, client money must be kept distinct from firm funds, and client assets must be duly registered.
We offer are able to offer assistance in managing client money and assets, drawing from our panel of specialists expertise in adhering to the FCA Client Assets Sourcebook:
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CASS Processes and Controls:
Our team collaborates with you to design or refine your CASS processes and controls, which may involve enhancing reconciliation procedures, record-keeping mechanisms, or streamlining CMAR processes for increased efficiency.
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CASS Risk and Control Framework:
Working closely with your team, we assess your business against CASS rules, identify CASS-related risks, and document existing controls to mitigate them effectively.
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CASS Policies and Procedures:
We take the lead in drafting comprehensive CASS policies and procedures tailored to your business needs, providing quality assurance input on drafts produced internally.
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Governance and Oversight:
We evaluate the adequacy of your CASS governance and oversight, including the review of management information, breach escalation protocols, committee terms of reference, and responsibilities under SMCR.
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Total Capture Reviews:
By scrutinizing all products and services, we assure the comprehensive capture of your client assets, ensuring correct segregation, safeguarding, and application of exemptions.
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CASS Resolution Pack Preparation and Testing:
We can assist in creating or reviewing your CASS Resolution Pack, including organizing surprise "mock FCA" requests to test your team's responsiveness to information deadlines.
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Additionally, we offer specialist CASS compliance advice and resources, addressing various issues such as prudent segregation, internal records creation, internal custody record checks, and handling complex technical queries. We can also provide additional resources for compliance monitoring, secondments, CMAR preparation, and due diligence of banks and custodians as needed.