S166 – CASS Tom and Business model for an investment manager

An investment manager had failed to ensure adequate arrangements to protect client assets. This gave rise to a potential for harm to the client and the protection of their client money and assets. 

The investment manager needed to remediate audit findings and evolve their operating model, controls and practices to ensure they met their obligations under CASS and could continue to offer services for clients. 

We delivered an immediate CASS and operating model assessment and addressing the audit findings and regulator enforcement areas, by adding a remediation plan and milestones. Clear workstreams, responsibilities and deliverables were agreed with the firm’s executives, the board and the regulator and delivering the program of work to rectify the weaknesses and issues identified, within the timeframes expected. 

We provided the client with governance and oversight of the change program, the business readiness and the new outcomes until full completion and deliverables and outcomes assessment post s166 period. We also offered ongoing CASS coaching, training & mentoring across the business.

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