The FCA’s Client Asset Unit carries out specialist and intensive supervision of client assets, with the aim of ensuring that firms have robust systems in place to ensure the swift return of client assets in the event of firm insolvency.
FCA’s formula for enforcement for client money breaches is driving heavy fines as well as significant remedial costs.
Typical failures in firms include the following;
- The failure to identify client money as client money, particularly in relation to;
- Intra-group arrangements; and
- Third party arrangements
- Failure to put trust letters in place
- Failure to train staff appropriately
Protecting your clients protects your Firm
CCL has the expertise to:
- review your CASS policies, procedures and control framework
- assist you in the design of robust CASS systems and controls
- review your governance arrangements to ensure proper control and reporting
- provide guidance on the interpretation and application of the CASS rules
Contact our Prudential Rules Specialists to discuss your CASS requirements