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Client Assets

Client money and custody assets (CASS) is a critical aspect of regulatory compliance. It’s an area in which our 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 gap analysis reviews, Section 166 project work, audit support, remedial projects and CASS training.

We can help with client money in a variety of ways:

    • Looking at your business processes and priorities and setting out the handling solutions available to you
    • Providing guidance on interpreting the TOBAs you have with insurers, so you can clearly understand their implications for client money handling and/or risk transfer
    • Talking you through the differences between statutory trust client accounts, non-statutory trust client accounts, and insurer trust accounts (risk transfer), and helping you ensure you establish these properly and use them correctly
    • Providing training for the individuals responsible for client money within your business.

Alternatively, we can offer more hands-on support, working closely with you to check your procedures against FCA rules and ensure there are no gaps.

Many brokers and intermediaries get into difficulties over FCA rules. But that doesn’t need to happen to you. We have the experience and the expertise to help you navigate the regulations safely, efficiently, and competitively.

CASS

The FCA’s rules on client money and custody assets (CASS) are a crucial aspect of regulatory compliance. It’s an area in which our visits often uncover breaches. Typically, that’s because of a failure to understand where and how 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 gap analysis reviews, Section 166 project work, audit support, remedial projects and CASS training.

Our services include:

Processes and controls

We can work with you to design or revise your CASS processes and controls. This 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. If you wish, 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

Our 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 a Section 166 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 our CASS training to your particular needs based on how CASS applies to your firm and the specific risks you face.

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 on banks, other client money providers and custodians.

For more information about our client assets services, call 0207 436 0630 to speak to a member of our expert team or email info@thistleinitiatives.co.uk.


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