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Client money and custody assets (CASS) is a critical aspect of regulatory compliance. It’s an area in which our consultancy visits often uncover breaches. Typically, that’s because of a failure to understand where and how the FCA client assets rules apply.

Our specialist CASS team has a broad and deep understanding of all aspects of client money and custody assets. We provide a wide range of specialist support, including section 166 project work, audit support, remedial projects and CASS training.

Specifically, our services include:

Processes and controls

We can work with you to design or revise your CASS processes and controls. That might involve refining your internal and external reconciliation processes or record-keeping mechanisms – or designing a more efficient process for handling your FCA Client Money and Asset Returns (CMARs).

Risk and control framework

Our team can design or revise a CASS risk and control framework for your business. Typically, we would do this by carrying out a gap analysis review of your business against current client asset rules. Working with your team, we’ll evaluate the CASS risks your business faces and document the controls you currently have in place for addressing these.

Policies and procedures

We can either draft your firm’s CASS policies and procedures from scratch or update documents you already have in place. We can take the lead and do the drafting for you or provide quality assurance input on something you’ve produced in-house.

Governance and oversight

Thistle’s expert team can assess the adequacy of your CASS governance and oversight. This would include reviewing management information, breach escalation, committee terms of reference, and the spread of responsibilities for the Senior Manager responsible for your firm’s CASS compliance – as well as the corresponding responsibilities of your CASS Operational Oversight certification function.

Client assets health check

We can help you assess the adequacy of your CASS controls. This could either be by carrying out a high-level review of your CASS arrangements or by carrying out a full review of your processes. This would enable us to make proportionate and effective recommendations for potential improvements to your client assets processes.

Section 166 support

If you’re facing an s166 review, one of our experts can act as your adviser. To help you prepare in advance for the possibility of a future s166 review, we can also carry out a mock review for you.  This will identify any areas requiring attention.

Resolution pack support

Current client assets regulations require firms to have a resolution pack in place that would enable an insolvency practitioner to achieve a timely return of assets to clients should you become insolvent. We can help you meet this requirement by drafting your CASS resolution pack from scratch or by testing whether your current one is fit for purpose.

Client assets capture review

To test whether you have properly captured your total client assets population, we can carry out a review of all the products and services you offer. Undertaking this exercise gives you the reassurance of knowing you’re segregating and safeguarding the correct assets and that you’re applying any exemptions correctly.

Audit support

Should you find yourself facing the prospect of a CASS audit we can help you prepare before the auditor arrives. Working with a CASS controls matrix, we can advise you on how to address audit findings before the official report is finalised – or we can support you with any remedial work required.

Specialist consultancy

We can offer expert professional advice on technical issues such as the creation of internal records. We can also advise on the relative merits of prudent segregation and pre-funding or how to use the internal system evaluation method for internal custody record checks.

CASS training

We can provide anything from one-to-one training for your senior staff to training in small groups across the whole business. We’ll tailor all CASS training to your particular needs based on how CASS applies to your firm and the specific risks you face.

We can help

In addition to all of the above, our expert team can work with you on a long- term basis to supplement your in-house resources. For example, we can help with ongoing CASS compliance monitoring, with regular CMAR preparation, or with carrying out due diligence of banks, other client money providers and custodians.

To find out more about how Thistle can help with all aspects of client money and custody assets compliance, contact our specialist CASS team today on 0207 436 0630 or email

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