CASS and Safeguarding
The FCA continues to expect regulated firms to keep assessing their system and internal controls. This is to achieve a good governance and control framework in order to comply with the FCA’s client assets protection regulations as set out in the following rules which we have subject matter experts in:
• CASS (Client Assets Sourcebook) – for investment and insurance business firms; and
• Safeguarding – for payment services and e-money provider firms.
• CASS (Client Assets Sourcebook) – for investment and insurance business firms; and
• Safeguarding – for payment services and e-money provider firms.
Current market challenges
Since the financial crisis of 2008 and the collapse of Lehman brothers, the protection of client assets has come under the spotlight, with firms coming under increased scrutiny regarding their governance from a CASS perspective.
Demonstrating governance and oversight are key aspects of compliance with client assets protection regulations. This is one of the many challenges faced by firms in that building a culture that promotes change and innovation must be balanced with ensuring governance remains at the forefront of a firm’s strategy. We aim to embrace our clients’ needs to adapt with ever changing market whilst also holding them accountable with their governance and oversight procedures.
The FCA has put a large focus on the firms’ use of IT and the importance of the firms’ understandings of the systems in use for compliance with the regulations and how they interact to provide the key relevant information including client records and reconciliations. We have a dedicated team of IT specialists with significant experience to provide a quality engagement from all angles.
How can we help
We have a wealth of experience of working with firms across all sectors, including asset managers, banks, brokers, custodians, capital markets, payment services and e-money provider firms.
We have deep understanding of various products and services offered to clients of those firms and have strong familiarity with typical transaction mechanism, various market participants involved, service providers and also the key systems and processes used.
Our core team of CASS and Safeguarding SMEs is continuously discussing the ever-changing landscape and fine-tuning our views on the interpretation of more technical and complex rules within the regulations.
As well as providing annual assurance reports, we also support the regulated firms in the risk and control gaps identification and remediation process.
Overall, we apply the same professional approach, methodology and principles as we would to any other assurance engagement in accordance with our robust assurance methodology.
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