Client Money and Custody

Whilst the principles embodied within the FCA’s Client Assets (CASS) Sourcebook are relatively mature and broadly understood, firms continue to put clients’ assets at unacceptable risk by failing to implement robust protection arrangements. Therefore, the protection of client money and safe custody assets remains a key priority for the FCA as the financial services industry develops more robust arrangements and controls.

Weaknesses in firms’ client asset systems and controls can cause serious financial detriment to customers and counterparties, as well as reputational damage to the firm and the financial markets.

How Duff & Phelps Can Help

Our experienced team comprises professionals with operations, compliance, regulator and audit backgrounds who are able to provide a range of support from a review of your CASS arrangements 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 i 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 Skilled Person Panel for Client Assets.

Our bespoke reviews are tailored to your specific needs and concerns. They enable you to gain confidence that you have a fit for purpose, robust CASS framework in place, thus minimizing the risk of regulatory investigations or subsequent sanctions and enforcement.

Our Services

• CASS Reviews: 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
• Skilled Person: Acting as Skilled Person with respect of CASS arrangements in line with Section 166 requirement notices or supporting a firm through the section 166 process
• Assurance: Providing assurance reports on the design and operating effectiveness of controls
  Change management: Designing, managing and implementing regulatory change programs including CASS
• Remediation: Assessing and remediating any CASS compliance issues
• CASS Governance: Assessing, reviewing and/or drafting CASS governance frameworks including committee terms of reference and management information templates
• CASS Resolution Pack (CASS RP): Reviewing your CASS RP and/or undertaking a simulated test of the CASS RP
• Client Money Asset Return (CMAR): Ensuring that your CMAR is accurate and assessing, reviewing or drafting policies to populate the CMAR
• CASS policies and framework: Reviewing or drafting CASS policies and operating procedures
• Internal System Evaluation Method (ISEM): Assessing whether you are able to perform an internal reconciliation or ISEM and advising on the design of the ISEM as required
• Training: Providing customized training to staff in key oversight positions and staff with CASS responsibilities
• Compliance monitoring: Designing, implementing and/or reviewing your CASS compliance monitoring arrangements. This includes an assessment of your regulatory footprint and putting in place a
• Compliance Risk Assessment (CRA): to reflect appropriate regulations, risks, gaps and mitigants.