Client assets are the most scrutinised area of FCA supervision. When CASS goes wrong — a segregation failure, a reconciliation error, a wind-down without a resolution pack — the consequences are immediate and severe. The FCA doesn't treat CASS failures as administrative oversights. It treats them as fundamental governance failures. The FCA doesn't wait.
What's included:
CASS firm classification and reporting: firm type categories, classification determination, annual CASS questionnaire, and CMAR obligations
Client money holding and segregation: definition, trust arrangements, client bank account management, and monitoring and controls
Safe custody assets: identification and segregation, third-party custodian arrangements, and custody risk assessment
Reconciliation and record-keeping: daily reconciliation, record-keeping standards, and internal audit and quality assurance
CASS Resolution Pack: wind-down triggers, client asset protection, client notification, and asset transfer and succession planning
Breaches and regulatory reporting: classification, FCA notification requirements, investigation procedures, and remediation
Training, competence, and accountability: CF10a CASS Oversight Function, Prescribed Responsibility allocation, and responsibility matrix + much more
Who is this for?
CF10a CASS Oversight Function holders, Compliance Officers, Operations Directors, and Boards at FCA-regulated investment and wealth management firms.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
View RegTechPRO pricing and packages →
Client assets are the most scrutinised area of FCA supervision. When CASS goes wrong — a segregation failure, a reconciliation error, a wind-down without a resolution pack — the consequences are immediate and severe. The FCA doesn't treat CASS failures as administrative oversights. It treats them as fundamental governance failures. The FCA doesn't wait.
What's included:
CASS firm classification and reporting: firm type categories, classification determination, annual CASS questionnaire, and CMAR obligations
Client money holding and segregation: definition, trust arrangements, client bank account management, and monitoring and controls
Safe custody assets: identification and segregation, third-party custodian arrangements, and custody risk assessment
Reconciliation and record-keeping: daily reconciliation, record-keeping standards, and internal audit and quality assurance
CASS Resolution Pack: wind-down triggers, client asset protection, client notification, and asset transfer and succession planning
Breaches and regulatory reporting: classification, FCA notification requirements, investigation procedures, and remediation
Training, competence, and accountability: CF10a CASS Oversight Function, Prescribed Responsibility allocation, and responsibility matrix + much more
Who is this for?
CF10a CASS Oversight Function holders, Compliance Officers, Operations Directors, and Boards at FCA-regulated investment and wealth management firms.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
View RegTechPRO pricing and packages →
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