Share with your friends
Compliance with ‘CASS’

Compliance with ‘CASS’

Compliance with ‘CASS’

Compliance with ‘CASS’ (or the ‘Client Assets Sourcebook’) has been in the spotlight since the failure of Lehman Brothers in 2008. Why the ongoing focus and what do regulated firms need to be aware of?

The principal objective of the FCA’s CASS Rules is to keep Client Assets safe in the event of a firm’s failure. A fundamental requirement of the CASS Rules is that firms must keep client money separate from firm money in segregated client money bank accounts and register custody assets appropriately. This ensures that client money and custody assets are ring-fenced in the event of the insolvency of the firm.

Ultimately, protecting clients is at the heart of these rules.

CASS has been an FCA priority for the past decade: the regulator has closely scrutinised firms’ arrangements during this time, and has issued multiple fines and public censures for firms and approved individuals alike where compliance has not met the required standards.

Given the ongoing regulatory attention, added to the fact that individuals will be more accountable than ever under the Senior Manager and Certification Regime (‘SMCR’), means that this is an optimal time to reassess your compliance arrangements.

How KPMG can help

Starting in the boardroom and working across your entire business, effective CASS management processes and controls need to be embedded into the core of your firm. KPMG can help you understand your requirements and enable you to make confident, well-informed choices that deliver outstanding results.

We have a market-leading team, experienced in working closely with the FCA, who have expertise across all types of organisations and in all areas of CASS operations.

So whether you need help in understanding how CASS impacts your firm, where the FCA is focusing or planning for Brexit, our team can help.

For more information about our CASS services, contact our team today.

Typical projects

We provide a wide range of services to a number of firms in the financial services industry, and always work with our clients to develop a scope that is tailored to their specific requirements.  Examples of typical projects we undertake include:

Core Assurance

  • Thematic or deep dive reviews including end-to-end control, CASS RP and CMAR reviews

Regulatory Change

  • Brexit passporting changes
  • Individual accountabilities under SMCR
  • Changes in the market/industry driven by the FCA 

Internal Assurance

  • Assisting compliance and internal audit in either a co-sourced or out-sourced capacity to scope and execute CASS monitoring reviews

Technology Solutions

  • CASS training – design and implementation of CASS training relevant to your firm’s requirements
  • CARTS tool – Our own in-house system driven CASS risk and control framework that can be tailored to your needs.

Join us for our regular CASS industry forums driven by issues faced by clients and latest regulatory developments 

Bespoke events driven by current client issues:

  • CASS SMF / CF10a forum – analysing the hot topics impacting firms’ CASS operations
  • Compliance forum – focusing specifically on the second line of defence
  • Internal audit forum – concentrating on the third line of defence

These events not only deliver insights into what the industry is focusing on but also allow you to share knowledge and observations within your peer group. In addition to this, KPMG share observations and learnings from our audit and advisory engagements and feedback from our regular contact with the FCA.

To sign up to these events please register your details here.

Keep track of our Partner updates published on this page, where we discuss the ways to optimise opportunity in difficult conditions and ensuring your business doesn't fall foul of enhanced regulatory measures.