Outcomes Monitoring – A Good Practice Guide
MoreCall: 0845 139 4444
Email: hello@square4.com
Call: 0845 139 4444
Email: hello@square4.com
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. CASS compliance is a priority area for the FCA given its consumer protection objective – when something goes wrong, the impact on clients can be significant. The rules are complex and provide constant challenge to firms and accountable individuals and for many years now, FCA have been 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.
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.
At Square 4 Partners, we are more than just a consultancy – we are a collective force of accomplished experts, dedicated to advancing and transforming the Equity Release and Later Life Lending sector.
Our dedicated team of specialist consultants have proven track record of delivering results that matter. We offer a comprehensive range of services that empower financial institutions to thrive in an ever-evolving landscape.
Advisory
Square 4 Partners’ advisory services are the bedrock of our reputation. Whether it’s navigating complex regulatory changes, optimising operational efficiency, or developing innovative business models, our experts deliver customised advisory solutions to drive growth, resilience, success and critically good outcomes for customers.
Resourcing
Our resourcing solutions are tailored to the unique needs of organisations. We understand that the right talent can make all the difference in achieving your strategic objectives. Our extensive network enable us to source and place top-tier professionals through to front line agents who align perfectly with your organisational requirements, ensuring that your team is equipped to excel.
Recruitment
Our recruitment services go beyond just matching skillsets – we match cultural fit and vision, ensuring that the professionals we place become valuable, long-term assets to your team. Our rigorous recruitment process is underpinned by our extensive industry knowledge, resulting in placements that have a lasting impact.
Learning and Development
In the dynamic world of compliance, continuous learning is paramount. Square 4 Partners’ learning and development programs are designed to equip your staff with the knowledge and skills necessary to stay ahead. Our customised training modules, crafted by industry experts, empower your team to adapt to emerging trends and navigate the challenges of the modern financial landscape.
Being able to explain to your customers how you safeguard their client 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.
Total Capture
Identifying all parts of a business where CASS has an impact underpins every aspect of CASS compliance. We can support you in reviewing your business to ensure that you have captured all areas where CASS requirements apply and are able to explain any CASS exemptions you make use of.
Building CASS processes and controls
We can help you to build CASS compliant operational processes and controls, whether you’re applying for CASS permissions for the first time or looking to revise existing processes. We have deep experience of designing processes and controls that meet FCA expectations and stand up to regulator and audit scrutiny.
Preparing CASS documentation
We can prepare CASS policies and procedures in a way that not only reflects the compliant processes you have in place, but also explains them in a way that auditors and the regulator will easily understand.
Defining custody models
Third party custodians can be an important part of many custody models but using them can provide challenges to firms. Whether it’s in defining the custody model being used, carrying out due diligence, preparing compliant custody agreements that align with client terms, we can help support you in avoiding pitfalls and making sure your third party relationships work well.
Health checks and monitoring
We can independently review the effectiveness of your CASS systems and controls, assessing how well they comply with regulatory requirements, expectation and industry standards. We can provide expert support to your internal compliance monitoring teams, to help ensure that they are equipped to provide appropriate second line challenge to your operational teams. We can also test your CASS Resolution Pack to assess how well it meets FCA content requirements and test how easily accessible and understandable it is to someone not familiar with the pack.
Governance and oversight
Good CASS governance is at the core of CASS compliance and we can support you in achieving this. We can help your governing body to understand the CASS risks the business is exposed to and how they should be managed and provide independent challenge to the prescribed responsibility holder or CASS Operational Oversight officer. We can advise on CASS governance structures, sit on committees in an advisory capacity, advise on how to compile useful management information and how it should be used.
Third party arrangements
When any third party is involved in providing CASS services, it is essential to ensure the basis for the involvement is clear and aligns with contracts and that the third party selected is the right one to provide the required services. We can help you to review third party contracts to ensure that it’s clear where CASS roles and responsibilities lie between you and the third party. We can help design processes and controls around due diligence and ongoing oversight to ensure that the third party has the authorisation, skills and expertise to deliver the service and does so in a compliant manner on an ongoing basis.
Breach remediation
Perfect CASS compliance isn’t always possible and most firms experience occasional breaches, but how you react to breaches will contribute to the CASS culture of your firm. We can help you set up core processes, controls and communications around breach identification and management. We can also help you remediate breaches, whether through redesigning processes to correct flaws or through adding controls that mitigate the risk of issues occurring.
Audit preparation and support
Most CASS firms need to have a CASS audit and they can be time consuming and costly. Our support can help you to ensure you’re well prepared for your audit and able to communicate your business and CASS controls in a way that your auditor will understand, maximising efficiency for the whole process. We can also help you prepare your management response or support you in providing challenge to your auditor, if appropriate.
S166 support
Our Square 4 team has experience of delivering CASS s166 reviews as skilled person as well as providing firm-side support to businesses undergoing CASS s166 reviews. We have the depth of knowledge and expertise required to deliver efficient s166 reviews, with clear communications throughout the process. We can also to help you to prepare for a s166 review and to support you in dealing with skilled person questions and challenge during a review.
We want to set up a new business line, can you help us to assess the CASS implications?
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.
Can you help us liaise with our auditor to get the best outcome?
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.
We want to upskill our team, so that we’re less reliant on external resource going forward, can you help with that?
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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