Many UK investment firms that hold and/or control client money and assets must undertake an annual CASS audit as required by the Financial Conduct Authority (FCA). With the FCA’s increasing focus on consumer protection and the safeguarding of client assets, it’s critical for firms to demonstrate robust compliance during these audits.
Julie Tuffrey, Associate Director at fscom, is a senior CASS specialist with over 30 years of experience. This blog outlines key steps to not only excel in your next audit but also enhance your firm’s practices in safeguarding client money and assets.
What you need to know about a CASS Audit
CASS (or Client Asset Sourcebook) audits are annual, retrospective evaluations to ensure that firms have maintained proper systems and controls to comply with relevant regulations throughout the year, and that they meet these regulations by year-end. Adherence to Principle 10 of the FCA’s Principles for Businesses, which mandates adequate protection for client money and assets, is crucial. This is a part of the FCA’s ongoing initiative to put consumer protection at the forefront of business activities—a trend that is expected to continue.
Preparing for a CASS Audit
Preparation for a CASS audit involves multiple facets:
- Understanding CASS Application: Firms must document where and how CASS applies to their operations and justify their compliance decisions.
- Employee Training: It’s vital that employees involved in CASS-related activities are well-trained to understand and fulfill these requirements.
- Robust Controls: Auditors will review how CASS has been applied across your business, emphasising the need for effective controls and governance, especially if third-party services are involved.
- Comprehensive reporting and record-keeping: Detailed documentation of all CASS-related activities, reconciliations, and incident management is essential. Auditors will scrutinise any long-standing issues or breaches particularly severely.
Learning from Past Audits
Our team at fscom has gained significant insights from preparing numerous firms for their CASS audits. We have identified eight common areas where auditors typically find issues:
- Acknowledgement letters
- Reconciliations
- Complete data capture
- Change management
- Controls and governance
- Policy accuracy
- Third-party management
- CASS record-keeping
Fostering a positive CASS culture
Creating a positive, proactive culture around CASS and risk management enables a more open and communicative environment within your company. Training and awareness are crucial; consider hosting or attending industry events and webinars to enhance understanding and compliance across your team.
How we can help
At fscom, our pragmatic experts are ready to assist your firm in preparing for your next CASS audit. We offer a comprehensive range of services including CASS health checks, gap analysis, pre-audit assessments, assurance reports, remediation packages, best practice frameworks, and bespoke training solutions. Our goal is to mitigate audit risks effectively and ensure your firm is fully prepared to protect your clients’ money and assets.
Take Action Today
Don’t wait until your next audit is upon you. Contact us today to discuss how we can help you improve your CASS preparedness and compliance, ensuring the best possible protection for your clients. Contact us now to get started.
This blog post is a general summary and is not a complete or definitive statement of the law. Specific advice should be obtained where appropriate.
