Client Assets (CASS)

While the principles embodied within the FCA’s Client Assets (CASS) sourcebook are relatively mature and broadly understood, there is still disparity in how firms apply these principles. 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 firms and the financial markets.

How Kroll Can Help

Our experienced team comprised of professionals with operations, compliance, regulatory and accountancy backgrounds are able to provide a range of support from a review of your CASS arrangements and training to bespoke advice on technical matters and assistance with the delivery of the regulatory change.

We adapt our approach to meet your requirements, offering timely and cost-effective solutions in line with regulatory requirements and industry best practice. In the UK, we are members of the TISA Client Assets Technical Committee and are on the FCA’s Skilled Person Panel for Client Assets.

Our tailored reviews enable you to gain confidence that you have a fit for purpose, robust CASS framework in place, minimizing the risk of regulatory intervention and safeguarding your client’s assets.

Our Services

• CASS Reviews – Undertaking bespoke reviews 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 protect client money or safe custody assets
• Skilled Person – Acting as skilled person, we can perform both ‘Review and Recommend’ and ‘Reasonable Assurance’ CASS Section 166 reviews, and are well placed to provide support 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
• Remediation – Assessing and remediating any CASS compliance issues and audit findings
• CASS Rule Mapping – CASS rule assessments for firms new to CASS or those expanding into new areas, including CASS rule mapping in line with industry standards to assist auditors meeting FRC standards, control advice and guidance
• CASS Governance – Assessing, reviewing and/or drafting CASS governance frameworks including committee terms of reference and management information templates
• Senior Manager Support – Provision of support to senior managers including the individual with the prescribed responsibility for the firm’s compliance with CASS
• 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
• CASS Reconciliations and Evaluations – Assessing your reconciliation methodology and outputs for cash and assets, including independence of records, calculations controls, and the approach to validation of custody positions through either reconciliation or the Internal System Evaluation Method (ISEM)
• Training – Providing customized training to staff in key oversight positions and those with CASS responsibilities
• Compliance Monitoring – Designing, implementing and/or reviewing your CASS compliance monitoring arrangements and Compliance Risk Assessments (CRA) to reflect appropriate regulations, risks, gaps and mitigants
• Safeguarding audits –  Annual audits of compliance with the Safeguarding requirements for Authorised Payment Institutions and/or Authorised E-Money Institutions regulated under the Electronic Money Regulations 2011 and/or the Payment Services Regulations 2017