- 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 a priority. The relevant rules are to be found in the FCA’s Client Money and Assets Sourcebook (CASS), with CASS 5 being the relevant section for those involved in insurance distribution. Intensive regulation allows the FCA to enforce hefty fines on those who fail to put in place adequate and appropriate management systems and controls.
Implementation of effective CASS procedures, ongoing reviews and maintenance are fundamental to conserving integrity, protecting consumers and ensuring that the risk of reputational damage caused by a failure of management oversight is mitigated.
Regulators expect a firm’s Board and Senior Management to implement strategies that reflect appropriate and effective governance through the application of robust oversight and reporting arrangements.
This three hour briefing is ideal for oversight staff and senior management who want to explore industry best practice in relation to ‘CASS 5 – Client Money: Insurance Distribution’, examples of enforcement action and the risks that the regulator expects firms to address.
This session will enable delegates to;
- Summarise the regulatory concerns in relation to CASS 5
- Describe key regulatory FCA principles and specific risks associated with handling of Client Money in insurance distribution
- Explain the practical implications of your firm’s Client Money 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
Under the Approved Persons Regime, CF10a is the controlled function accountable for the safe handling of Client Money, as well as providing the Board with reassurance that the business is CASS compliant. The new accountability regime (SM&CR) will impose a certification process for the protection of client money.
The Course Agenda
CASS 5 – The fundamentals
- Understanding the background and drivers of the CASS 5 requirements
- FCA Principles and objectives for CASS
- 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:
- Contractual and Acknowledgement letters
- Segregation & Risk Transfer
- Importance of policies and procedures
- Records, accounts and reconciliations
- Reporting responsibilities to clients and the FCA
- Examine regulatory changes falling out of IDD
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 Money
Meet The Tutor
Mark has over 30 years’ experience in Financial Services and as a consultant he has broad CASS experience, including the design and implementation of client money processes and bank account structures of platforms, service providers and asset managers. In addition, he has undertaken remediation of processes and reconciliations, operating model design, outsource provider and system selection.
Mark’s CASS experience also includes the management of remediation of reconciliations, design of new reconciliation processes and calculations; definition and implementation of cash processing functionality, including the incorporation of audit requirements for CASS and expert advice on best practice. Design and delivery of appropriate staff training at all levels; the review and remediation of procedures and processes; practice FCA style interviews for senior staff have also been delivered.
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
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