Skilled Person Report to evaluate the CASS control environment of a Peer to Peer lender
The client was required to obtain a Skilled Person Report to provide an evaluation of its client money systems and controls focussed materially on the flows of client money within the firm and between the firm and third party organisations
We obtained documents and a detailed understanding of the client money flows, considering how money moved between the firm’s different legal entities (when prefunding) and then how client money was deployed, segregated, reconciled and held.
Having understood the cash flows, we assessed the firm’s approach to reconciling client money and handling both shortfalls and excess funds, assessing how effectively the firm was able to demonstrate a clear articulation of how each client’s money was allocated to different loan products.
We delivered a report that provided comfort to the regulator of the firm’s control adequacy and helped the firm identify and implement enhancements to its overall CASS control environment proportionate to its business model.