- Validating Your CASS Arrangements
21 November, 2019
9:30 am - 12:30 pm
- City of London
Are your senior management, CASS oversight team and board members aware of the impact the CASS rulebook could have on your business?
The Financial Conduct Authority (FCA) has made the protection of Client Money and Assets (CASS) a priority. Intensive regulation allows the regulator to enforce hefty fines on the industry for the lack of appropriate management and oversight. The Client Money and Assets Return report (CMAR) gives the FCA the ability to monitor firms remotely. The CASS Resolution Pack provides a simple way for the FCA to check compliance and brings new impetus to FCA spot checks; firms can have the regulators in their businesses with minimal notice of the FCA informing them of a visit.
CASS implementation, ongoing reviews and maintenance are fundamental to conserving integrity, protecting consumers and ensuring that reputational risk of a lack of management oversight is mitigated.
Regulators expect the Board and Senior Management to implement strategies within their firms that reflect appropriate and effective policies, procedures and processes;
This three hour briefing is for oversight staff and senior management to explore lessons learnt from industry best practice, recent enforcement action and the risks that they are expected to address by the regulators. This session will enable delegates to;
- Summarise the regulatory concerns in relation to Client money and Assets (Client Assets)
- Describe key regulatory FCA principles and Client Assets specific risks
- Explain the practical implications of your firm’s Client Assets responsibilities
- Challenge effectively your current governance and operational oversight framework.
CASS Systems and Controls
Continual review of your firm’s structure and processes to minimise the risk of non-compliance. Our expert and practical advice will help you to ensure that you implement the necessary systems and controls.
Keep pace with a moving target
Changes in the global regulatory environment, implies a continuing pressure to review and update CASS requirements. In order to keep up with regulation and anticipate future changes, it’s essential to seek expert advice on the regulator’s position as soon as it emerges.
Internal Oversight of CASS
CF10a is the control function accountable for the protection of Client Money and Assets as well as reporting to the Board of a firm that the business is CASS compliant. The new accountability regime will impose a certification process for the protection of client money and assets as it is important for firms to identify the impact across the firm for assigning accountability and responsibility for CASS.
The CASS Sourcebook an untold story
The CASS sourcebook is divided into two policies. Policies that firm’s must pursue daily and policies that stay dormant till a firm enters insolvency. Knowing the structure of the Sourcebook, and the other parts of the regulatory handbook are crucial.
The Course Agenda
The fundamentals of CASS
- Understanding the background and drivers of new requirements
- State the FCA Principles and Objectives for CASS protection
- Provide examples of FCA CASS enforcement
- Explain the scope of rules and guidance including cross-jurisdictional impacts
- State the high level requirements for the protection of Client Money and Assets including:
- Contractual and Acknowledgements letters
- Importance of policies and procedures
- Records, Accounts and Reconciliations
- Understanding the funding and necessary review process
- Reporting responsibilities to the clients, the regulator and the auditing reporting requirements
- FRC requirements and update
- Client Money and Asset Return
- CASS Resolution Pack
- Examine regulatory changes including MiFID II, impact of Brexit and political uncertainty in the global market.
Operational and Regulatory Oversight
- Examine risks associated with third party agreements; service level agreements and management information, including those intra-group
- Explore what meaningful management information and oversight is required for board assurance
- Discuss the role of the regulator and the FCA’s approach to the protection of Client Assets
Meet The Tutor
Karen has more than 31 years’ financial services experience and has been a consultant since 1999. Assignments delivered include support for the development and setting up of operational processes, including client money procedures; selection and implementation of outsource providers; operational transformation and strategic propositional advice. She has worked for a wide variety of firms, including platforms and their software providers, wealth managers, asset managers and outsource providers.
Other experience includes the review, benchmarking and selection of systems for front offices and operational areas; business process review and operational model design; and regulatory support, reviews, remediation and training covering CASS, RDR, ISA administration, MiFID and TCF. In addition to her consultancy experience, Karen was COO of a private client stockbroker, responsible for in-house custody, systems, settlement and all other aspects of client service. She was also Head of Private Client Administration at a wealth manager and held various supervisory and management roles at the London Stock Exchange, including a customer services role covering all small to medium sized brokers and all related software houses.
Who is this course for?
Delivered by experts, this update is written for:
- Staff involved with client money and assets, including board members and senior managers
- Individuals performing the CASS Operational Oversight function (CF10a)
- Compliance teams
'This was an extremely engaging session, conducted by a very knowledgeable individual who made adequate time for questions.'
Private Client Investment Firm
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