FCA CASS Rules

Session 1: Introduction to Client Assets Sourcebook: Foundational Principles

• Purpose of CASS: Why the rules exist and the FCA's core objectives (e.g., consumer protection, market integrity).
• Scope and Applicability: Identifying which firms are subject to the Client Assets Sourcebook and the distinction between CASS medium and large firms.
• Key Concepts: Defining "Client Money" and "Custody Assets."
• The CASS Resolution Pack (CASS RP): Its purpose and key components.

Session 2: CASS 7 - Client Money Rules

• The Client Money Trust: The legal basis for holding client money.
• Segregation Requirements: The need to keep client money separate from firm money in a client bank account.
• Acknowledgement Letters: Requirements for obtaining and maintaining valid acknowledgement letters from banks.
• This CASS course explores common breaches: Discussion of frequent CASS 7 breaches, such as delays in segregation and lack of proper records

Session 3: CASS 6 - Custody Rules

• Holding Safe Custody Assets: The rules for firms that hold or control investments on behalf of clients.
• Segregation and Record-Keeping: Requirements for identifying and segregating client assets from firm assets.
• Third-Party Custodians: Due diligence and ongoing monitoring requirements for third parties.
• Reconciliations: The need for daily internal and external reconciliations for custody assets.

Session 4: Reporting, Mandates, and Other Rules

• CASS 10 - The Client Money and Asset Return (CMAR): Who needs to submit it and the information it contains.
• CASS 8 - Mandates: The rules governing firms acting under a client mandate.

Session 5: Governance, Controls & Enforcement

• CASS Governance Framework: The roles of the Board, senior management, and the CASS oversight function.
• Senior Managers & Certification Regime (SM&CR): The responsibilities of individuals, particularly the CASS Responsible Director.
• Audit: What auditors look for and how to prepare.
• FCA Supervision and Enforcement: The regulator's approach, common themes from Dear CEO letters, and the consequences of serious breaches.

Conclusion - Summary, Questions and Open Forum

• CASS courses conclude with an open forum to be participant-led and may include the following:
  
  • Perceived challenges
  • Perceived unknowns
  • Successful past practices

With over 20 years of training experience in financial services, Redcliffe's CASS training leader is well-placed to support you across compliance-related topics.

He is a former Head of Education for HSBC covering the UK and Europe. In this role, he was responsible for regulatory and financial crime-related compliance learning. His time at HSBC was during intense scrutiny from regulators and government functions during the bank’s Deferred Prosecution Agreement.

His other roles include leading the Monitoring and Testing programme for a UK Wealth Manager. As well as the Senior Vice President responsible for Global Risk & Compliance training at a US-based bank.

He worked in the Insurance Firms division at the Financial Conduct Authority (in the FSA days). Here, he was the divisional expert for the FCA CASS rules and outcomes required under the Training & Competence handbook. The HSBC role and five years at Barclays in their Private Clients and Wealth functions include retail, commercial, wholesale and private banking channels.

Since leaving HSBC, he has worked with the compliance, HR and operational teams of firms. He has helped enhance their regulatory understanding. He has also delivered content to private equity firms, investment houses, banks and wealth managers.

He often delivers core programmes for TISA and the Investment Association. Our CASS course trainer is a former member of the Investment Management Association Training & Education Committee. He won the Thomson Reuters award for “Most Effective Compliance Training at a Regulated Firm” in 2010.

Redcliffe’s FCA CASS training enables you to:

• Gain a toolkit to assess your frameworks against a series of effective controls
• Identify areas requiring strengthening.
• Support ‘reasonable steps’ to ensure regulatory compliance with handling and protecting client money and safe custody assets.
• Support open discussions amongst representatives of firms on both challenges experienced and actions to overcome them.
• Promote a clear narrative on how the Prescribed Responsibility for the firm’s compliance with CASS is discharged.
• Understand how to better prepare for a CASS.

FCA CASS training is vital for those involved in Client Assets Sourcebook operational oversight. Also, professionals who are taking on more responsibility in this area, including:

• Risk & Compliance professionals
• Operational team members and leaders in relevant teams
• Internal Audit professionals
• Business Assurance teams

CASS training courses at Redcliffe provide a comprehensive and accessible introduction to the UK Financial Conduct Authority's (FCA) Client Assets Sourcebook. Its primary purpose is to equip professionals within the financial services industry with the fundamental knowledge needed to understand and comply with CASS regulations.

By focusing on core principles, the course ensures that participants are well-versed in the rules designed to protect client money and custody assets. Thereby safeguarding consumers and maintaining confidence in the financial markets.

The curriculum covers several critical areas essential for anyone working with client assets. It delves into:

• The specific purpose of the CASS rules
• Explores their scope and applicability by defining the thresholds for different firm sizes
• Clarifies the crucial distinction between "client money" and "custody assets"

This course also provides a detailed breakdown of the Client Assets Sourcebook Resolution Pack. We explain why it is a vital document and outline its key components, which are essential for facilitating an orderly return of client assets in the event of a firm’s failure.

Ultimately, participants who complete this workshop gain a solid foundation in regulatory compliance. You will be able to identify key CASS rules, understand how to apply them in your day-to-day roles, and appreciate the significance of proper record-keeping and segregation of assets.

Please note: Redcliffe's FCA CASS training courses are deliverable as a virtual classroom or in-house.