CASS and Safeguarding
We are seeing increasing focus and elevated numbers of Skilled Persons Reports regarding CASS. Adequate and effective safeguarding of clients’ assets and money should be a fundamental element of relevant firms’ systems and controls. Stringent requirements are set out in the FCA’s CASS Handbook, including safeguarding rules under CASS 15.
The FCA is not tolerant of deviations from the CASS requirements. Supervisors see the CASS rules as an important retail consumer protection. CASS compliance may ultimately be tested in insolvency proceedings, where minor documentation errors can result in loss of trust status and protection. Hence supervisors will insist on detailed and painstaking compliance.
Attention is being placed on all elements of the CASS framework including Governance and personal accountability, reconciliation arrangements, acknowledgement letters, resolution packs, Client Money and Assets Reporting (CMAR) and the oversight of third parties. Recent Dear CEO letters have reminded all firms of the importance of CASS controls, including the oversight of third parties where custody is arranged with another party.
Our Approach
Our tailored approach aligns with the business model of the firm and the nature of its CASS arrangements. We offer solutions that are proportionate to the scale of the business and the regulatory, operational and reputational risks it faces, as well as the safeguarding risks posed by the firm’s CASS controls.
Our team has worked in financial services institutions in front and back office, compliance and risk leadership roles and as regulatory consultants. Every team allocated to an assignment will have the relevant technical skills to deliver proactive, sustainable solutions.
Our Solutions
Design and Implementation of the CASS or Safeguarding Framework
Design of, or specific advice on, the CASS or safeguarding systems, processes and controls. This may be specific to certain elements (e.g. client money, reconciliations) or end-to-end operating models for a firm’s CASS or safeguarding framework.
"Shadow" CASS and Safeguarding Audits
Assessing independently a firm’s controls in preparation for formal CASS and safeguarding (CASS 15) audits.
Assessments of CASS Arrangements
Assessing specific elements of the CASS processes and/or end-to-end the Firm’s CASS arrangements in conjunction with the firm or on an independent basis.
CASS Training
All elements of CASS applicable to the firm and/or more targeted CASS training focussed on process, team or control.
CASS Governance
Ensuring that CASS Governance is adequate, effective and aligned with the broader governance framework of the firm.We support front and back office design, implementation and review. We help firms enhance their CASS control environments and compliance and risk functions to ensure that their frameworks have full coverage and are operated effectively.
