CASS and Safeguarding

We are seeing increasing focus and elevated numbers of Skilled Persons Reports regarding CASS. Adequate and effective safeguarding of clients’ assets and money (CASS) should be a fundamental element of all firms’ systems and controls.

Attention is being placed on all elements of the CASS framework including Governance and personal accountability, reconciliation arrangements, acknowledgement letters, resolution packs, Client Money and Assets Reporting (CMAR) and the oversight of third parties. Recent Dear CEO letters have reminded all firms of the importance of CASS controls, including the oversight of third parties where custody is arranged with another party.

Our Approach

We work with all firms who have CASS requirements including banks, asset managers, private banks, brokers and global custodians. Our tailored approach aligns with the business model of the firm and the nature of its CASS arrangements. We offer solutions that are proportionate to the scale of the business and the regulatory, operational and reputational risks it faces, as well as the safeguarding risks posed by the firm’s CASS controls. Our team has worked in financial services institutions in front and back office, compliance and risk leadership roles and as regulatory consultants. Eachteam allocated to an assignment will have the relevant technical skills to deliver proactive, sustainable solutions.

Our Services

We offer a range of services including Skilled Person assignments, independent assurance reviews, advisory mandates and training. We support firms with:

Safeguarding Audits

Assessing independently a firm’s controls for CASS safeguarding.

Assessments of CASS Arrangements

Assessing specific elements of the CASS processes and/or ‘end-to-end’ the Firm’s CASS arrangements in conjunction with the firm or on an independent basis.

CASS Training

All elements of CASS applicable to the firm and/or more targeted CASS training focussed on process, team or control.

CASS Governance

Ensuring that CASS Governance is adequate, effective and aligned with the broader governance framework of the firm.

We support front and back office design, implementation and review. We help firms enhance their CASS control environments and compliance and risk functions to ensure that their frameworks have full coverage and are operated effectively.