FCA CASS Rules

Become an expert in the Revised Auditing Standard & SMCR Responsibilities

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A half-day FCA CASS training

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Download: Course Outline

Session 1: Overview: Where Are We Now?

The impact of COVID-19
Current position: What we should have done already and what’s next?
Summary of recent regulatory publications related to CASS management and FCA-identified issues, such as incorrect TTCA procedures
How have we enabled a staff response to the new way of working? What do we now need staff to know and do differently?

Session 2: Oversight & Culture

Establish/Implement/Maintain: What’s needed to maintain a compliant framework?
Tone from the top: link to the Prescribed Responsibility Holder
Culture; you get what you tolerate
Positive reinforcement of activity around clients’ assets and the link to the SMCR Individual Conduct Rules
What extra do we need to do to ensure appropriate oversight?
The fundamental risks to good CASS governance
Changed CASS reporting flows and Management Information
CASS Audit – revised Client Asset Assurance Standard (November 2019)

FCA CASS Workshop – build the list of questions we’d expect the FCA or CASS Auditor to ask us. Individual input on questions you’d rather not be asked, so we may focus on what’s needed to answer them robustly.

Session 3: Resolution Packs, Documentation & New Considerations

The core content of the pack: immediate and 48-hour retrieval
Pack management: awareness/change management/ownership
Systems access: changes in procedure in 2020
Retrieval testing in a remote working environment
Changing reliance on third-party providers and associated persons
Revised due diligence measures on third parties

Session 4: CASS Through an SMCR Lens

Senior Managers: prescribed responsibilities and reasonable steps
Certification function: CF10a role holders and beyond
Conduct Rules: how applied, communicated, trained/assessed and monitored
Creating and documenting effective CASS oversight of delegation

DISCUSSION – changes seen within your firm and challenges being addressed

FCA CASS Course Conclusion – Summary, Questions and Open Forum

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 FCA CASS Rules course expert 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), where 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 have seen him work with retail, commercial, wholesale and private banking channels. Since leaving HSBC, he has worked with the compliance, HR and operational teams of firms to enhance their regulatory understanding, as well as delivering 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 course details are as follows:

Gain a toolkit to assess your frameworks against a series of effective controls. You will also identify areas requiring strengthening.
Support ‘reasonable steps’ to ensure regulatory compliance with handling and protecting client money and safe custody assets.
To support open discussions amongst representatives of firms on both challenges experienced and actions to overcome them.
An overview of regulatory comments from the last 12 months on expectations of compliance with the CASS rulebook.
Promote a clear narrative on how the Prescribed Responsibility for the firm’s compliance with CASS (Client Assets Sourcebook) is appropriately discharged.
You'll receive an overview of the CASS Auditor’s focus as per the Client Asset Assurance Standard (revised November 2019).

FCA CASS training considers the changing environment and how our control CASS frameworks must adapt to remain compliant.
We have designed this course to share practical lessons and good practice techniques. Participants are more than welcome to contribute here.
We look at FCA publications (guidance and Dear CEO letters). This is to understand the identified issues, the expected responses and how we can install them.
Our FCA CASS Rules course is developed and delivered by a professional trainer. He has experience in designing and delivering regulatory training programmes across complex organisations.
The session is directly relatable to FCA Prescribed Responsibility 11 (reference z) – Responsibility for the firm’s compliance with CASS.

FCA CASS training is vital for those involved in CASS operational oversight and who are taking on more responsibility in this area.

Furthermore, it’s useful for senior managers who need to understand what reasonable steps to take to ensure SMCR compliance. It also benefits those wanting to understand the regulatory viewpoint and how it relates to operational activity, as well as those in monitoring and testing, risk or audit-type roles and compliance officers.

2020 gave us some unexpected priorities and much-altered working patterns. Against this, we still need to focus on the expectations of the regulator. With new ways of working come new challenges. Keeping the constant flows of cash and assets identified, segregated and reconciled was challenging enough in the office. Let alone our own and our third-party partners working remotely.

Redcliffe's CASS online courses do not seek to teach the rules of the CASS handbook. Instead, it considers our existing practices against a changing environment on the impact of COVID-19, revised audit standards, SMCR implications and ongoing regulatory comments based on FCA’s assessment of firms.

Please note that Redcliffe's FCA CASS training courses can be delivered as a virtual classroom or in-house.

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