The principal objective of the FCA’s CASS Rules is to keep Client Assets safe in the event of a firm’s failure. A fundamental requirement of the CASS Rules is that firms must keep client money separate from firm money in segregated client money bank accounts and register custody assets appropriately. This ensures that client money and custody assets are ring-fenced in the event of the insolvency of the firm.
Ultimately, protecting clients is at the heart of these rules.
CASS has been an FCA priority for the past decade: the regulator has closely scrutinised firms’ arrangements during this time, and has issued multiple fines and public censures for firms and approved individuals alike where compliance has not met the required standards.
Given the ongoing regulatory attention, added to the fact that individuals are more accountable than ever under the Senior Manager and Certification Regime (‘SMCR’), means that this is an optimal time to reassess your compliance arrangements.
How KPMG can help
Starting in the boardroom and working across your entire business, effective CASS management processes and controls need to be embedded into the core of your firm. KPMG can help you understand your requirements and enable you to make confident, well-informed choices that deliver outstanding results.
We have a market-leading team, experienced in working closely with the FCA, who have expertise across all types of organisations and in all areas of CASS operations.
So whether you need help in understanding how CASS impacts your firm, where the FCA is focusing or ways to achieve an enhanced CASS operating model, our team can help.
For more information about our CASS services, contact our team today
Typical projects
We provide a wide range of services to a number of firms in the financial services industry, and always work with our clients to develop a scope that is tailored to their specific requirements. Examples of typical projects we undertake include:
Core Assurance
- Thematic or deep dive reviews including end-to-end control, CASS RP and CMAR reviews
- Assisting compliance and internal audit in either a co-sourced or out-sourced capacity to scope and execute CASS monitoring reviews
CASS Change Projects
- Assisting with driving CASS transformation (e.g. as part of remediation activity / CASS target operating model programmes)
Regulatory Developments
- Individual accountabilities under SMCR
- Changes in the market/industry driven by the FCA, including digital assets regulations
Technology Solutions
- CASS training – design and implementation of computer-based CASS training relevant to your firm’s requirements
Join us for our regular CASS industry forums and Webinars driven by issues faced by clients and latest regulatory developments.
January 2024
It was a pleasure hosting the CASS SMF Forum in person this time around at KPMG’s offices in London and Edinburgh.
There was some interesting and lively discussion in the room and if you wish to revisit the presentation, please find the link below:
KPMG CASS SMF Forum 2024opens in a new tab
Headlines from the event
- Market Updates – an update on the regulator’s current CASS areas of focus and trends in the market.
- Digital Assets – KPMG's view on how the proposed crypto and digital assets regulations will impact CASS requirements and discussing the implications of launching your own Digital Asset.
- Artificial Intelligence – a discussion on Artificial Intelligence in the Banking and Investments space and potential opportunities.
- Spotlight on CASS remediation – key CASS challenges we are seeing in the market, the drivers for transformation and success factors.
- Audit observations - KPMG observations from the 2023 cycle.
We would be happy to pick up further on any of the points covered so please don’t hesitate to reach out.
KPMG CASS Health Check
How ready is your firm for a visit from the FCA? At KPMG we can help by simulating a short notice visit from the FCA.
CASS RP Reiew
The CASS RP is often the starting point for the FCA to see how seriously firms take CASS compliance and whether they properly understand their obligations.
KPMG CASS Training
KPMG have designed multiple training services which we offer to our clients to help them meet their specific training requirements.
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