What is CASS?

The Client Assets Sourcebook (CASS) sets out the rules which a firm must adhere to when holding and controlling client money or safe custody assets. It is clear is that these rules have been drafted to protect client money and assets in the case of insolvency. What is less clear, is just how these rules are to be implemented, and what exactly they mean for MiFID firms.

What are the expectations of firms in relation to CASS?

CASS requires firms to minimise their risk of financial loss by identifying, assessing and mitigating risks. It imposes the obligation to report to the FCA on the value of the client assets they hold. It is the amount of client money and/or custody asset holdings which will determine its CASS classification. That is, whether they are a small, medium or large firm.

This classification will also determine what further obligations the firm must uphold, such as completing a CMAR or appointing a CASS Operational Oversight officer. Other key requirements include:

• creating and maintaining records and accounts to identify client assets
• conducting internal and external reconciliations
• establishing adequate organisational arrangements for the safeguarding of client assets
• creating and maintaining a CASS Resolution Pack.

How can we help?

You can benefit from our team’s experience in working with all aspects of CASS including:

• Governance, oversight and third party controls
• CASS policies and procedures
• CASS audits preparation
• Remediation projects
• CASS resolution packs
• CASS training

If you are looking for CASS compliance support from the leading experts in the industry, contact us today for a free initial consultation.