Client Assets (CASS)
The protection of client money and custody assets continues to receive global regulatory focus as the financial services industry develops more robust arrangements and controls. Never before has so much focus been given to attention to detail in complying with these regulations.
For example, in the UK, the FCA published PS14/9 in June 2014, a significant publication making changes to the Client Asset (CASS) rules, and is the latest milestone in the efforts of the regulator to ensure that lessons from the past have been learnt. There was a phased introduction of the required changes running through to 1 June 2015, with some of the requirements representing material change to operational processes that require significant consideration and planning for affected firms.
How Duff & Phelps can help
Fund managers, wealth managers, administrators and any other firms with permission to safeguard and administer client money and assets, or those responsible for arranging protection, may find the services that we can provide useful.
Our experienced team comprises staff with operational, compliance and audit backgrounds who are able to provide a range of support from an assessment of compliance health and training to providing bespoke advice on technical matters and assistance with the delivery of the regulatory change.
We are able to adapt our approach to meet your requirements, offering timely and cost effective solutions in line with regulatory requirements and best industry practice. In the UK, we are members of the TISA Client Assets Technical Committee and Client Assets Best Practice Working Group and have been appointed to the FCA Client Asset Skilled Persons Panel.
Our bespoke reviews seek to identify opportunities for improvements to processes and procedures that would reduce the risk of failure to protected client money or safe custody assets.
Our experienced, multi-disciplinary team can assist you with:
- Undertaking bespoke reviews of some or all of your CASS arrangements (including CASS governance arrangements) to identify opportunities for improvements to processes and procedures that would reduce the risk of failure to protected client money or safe custody assets
- Acting as Skilled Person with respect of CASS arrangements in line with FCA’s Section 166 requirement notices
- Providing assurance reports on the design and operating effectiveness of controls
- Designing, managing and implementing regulatory change programmes including CASS
- Assessing and remediating any CASS compliance issues
- Reviewing your CASS Resolution Pack (CASS RP) and/or undertaking a simulated test of the CASS RP
- Ensuring that your Client Money Asset Return (CMAR) is accurate
- Assessing whether you are able to perform an internal reconciliation or an internal system evaluation method (ISEM) and advising on the design of the ISEM as required
- Providing customised training to staff in key oversight positions to assist in the benchmarking of your control environment
- Designing, implementing and/or reviewing your CASS compliance monitoring arrangements