Client assets are held on trust. That single legal fact creates obligations that sit above and beyond the normal regulatory framework — and the FCA enforces them accordingly. A segregation failure, a misallocation, or a reconciliation failure isn't just a compliance breach — it's a breach of trust law, with consequences for clients, the firm, and the SMF holder personally. The FCA doesn't wait.
What's included:
Governance and accountability: CF10a/SMF18 CASS Oversight Function, Prescribed Responsibility (z), governing body oversight, and management information framework
Client asset definition and classification: safe custody assets, client money, segregation requirements, and mixed remittances
Safeguarding and segregation: client money and safe custody asset segregation, third-party custodial arrangements, and internal controls
Third-party due diligence: assessment and selection criteria, contractual requirements, ongoing monitoring, and escalation procedures
CASS Resolution Pack and insolvency planning: resolution pack requirements, asset location systems, insolvency procedures, and regular testing
Risk assessment and internal controls: risk identification, control framework, mitigation strategies, and ongoing monitoring
Training, competence, and monitoring: mandatory training, competency assessment, daily monitoring procedures, and internal audit + much more
Who is this for?
CF10a/SMF18 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 held on trust. That single legal fact creates obligations that sit above and beyond the normal regulatory framework — and the FCA enforces them accordingly. A segregation failure, a misallocation, or a reconciliation failure isn't just a compliance breach — it's a breach of trust law, with consequences for clients, the firm, and the SMF holder personally. The FCA doesn't wait.
What's included:
Governance and accountability: CF10a/SMF18 CASS Oversight Function, Prescribed Responsibility (z), governing body oversight, and management information framework
Client asset definition and classification: safe custody assets, client money, segregation requirements, and mixed remittances
Safeguarding and segregation: client money and safe custody asset segregation, third-party custodial arrangements, and internal controls
Third-party due diligence: assessment and selection criteria, contractual requirements, ongoing monitoring, and escalation procedures
CASS Resolution Pack and insolvency planning: resolution pack requirements, asset location systems, insolvency procedures, and regular testing
Risk assessment and internal controls: risk identification, control framework, mitigation strategies, and ongoing monitoring
Training, competence, and monitoring: mandatory training, competency assessment, daily monitoring procedures, and internal audit + much more
Who is this for?
CF10a/SMF18 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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