Service Overview

The FCA’s Client Asset (CASS) rules are intended to keep client assets safe so that they can be returned to clients in the event of a firm’s failure.

The rules are complex and provide constant challenge to firms, the FCA have been focussing on CASS compliance for many years now, holding firms and individuals to account when they get things wrong. It’s also one of the few areas where the FCA will receive an independent report on your compliance with the CASS rules each year, enabling them to take an informed approach to supervision. It’s also an area of the rules with consumer protection at the core and where if something goes wrong, the impact on clients can be significant.

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Service Benefits

  • Being able to explain to your customers how you safeguard their assets is an important part of a successful business. Giving customers the assurance that their assets are safe with you can help underpin a thriving business.
  • Staying on top of CASS compliance will help you give confidence to the FCA that you understand what’s expected from you to ensure good CASS compliance.
  • The use of dedicated subject matter expertise can help you save money in the long run, enabling you to find the best solution first time, minimising the risk of breaches or costly remediation later on.

Examples of our work

How Square 4 can help

We have deep experience of delivering CASS advisory and assurance support. Our team members take a solutions-focussed approach and are adept balancing the CASS requirements with the commercial and operational realities of business. Our team has experience of CASS s166 reviews, including carrying out the review or supporting clients throughout the review. We have helped with remediation when firms have been under the FCA spotlight, set up new CASS processes and controls and supported governance teams in CASS oversight. We are ready to support CASS advisory and assurance requirements across all sectors. Our goal is to support you in achieving good CASS compliance whilst providing your team with the skills and knowledge they need to maintain those high standards.

FAQ

Q: We want to set up a new business line, can you help us to assess the CASS implications?

A: Yes. We often help firms carry out total capture exercises to identify all of the CASS touchpoints in both new and existing business lines. We can work with you to understand the new offering, how it aligns with your existing control framework and what new CASS risks will need to be managed.

Q: Can you help us liaise with our auditor to get the best outcome?

A: We can help you throughout the audit, ensuring that auditor requests are coordinated and dealt with in an efficient manner and in a way that provides the auditor with the right information at the right time. We can also support you in preparing your management response to your audit report to make sure that it gives the FCA clear information around the nature and causes of the breaches identified and the action you’re taking to remediate.

Q: We want to upskill our team, so that we’re less reliant on external resource going forward, can you help with that?

A: Our long-term goal with any of our CASS work is to make sure that your teams are put in a position where they can own and run processes themselves and most importantly, give them the skills to quickly spot when something goes wrong. We will always aim to equip your team for success going forward whilst providing a helping hand whenever needed in the background.

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