CASS Client Money & Assets — RegTechPRO - Modular Compliance Software

The CASS Problem

When the FCA reviews your client assets, a spreadsheet of bank balances won't pass.

CASS is the FCA's most prescriptive sourcebook, and CASS breaches are among its most heavily fined failings. Yet most firms still run it on spreadsheets, shared drives and consultant decks. The rules expect a client-money calculation — for many firms, every business day — with same-day top-ups, reconciliations performed and resolved on a strict cadence, a resolution pack retrievable in 48 hours, and an annual CASS audit. Not a folder of files.

The Client-Money Calculation Lives in a Spreadsheet

CASS 7.15 / 7.16 require you to calculate your client-money resource against your requirement — for many firms every business day — and pay in any shortfall by close of business. One broken formula, one missed day, and you have a reportable breach. A spreadsheet can't prove you got it right, on time, every day.

CM_calc_Mar_v3.xlsx

Client_bank_balances_FINAL.xlsx

Recon_working_v2_USE_THIS.xlsx

Reconciliations You Can't Prove You Did

CASS 6.6 and 7.15 require internal and external reconciliations on a fixed cadence, with every discrepancy investigated and resolved without delay. When the FCA or your CASS auditor asks, they want to see each one performed, dated, signed off and reconciled — not a promise that it usually happens.

Internal CM recon — last done? Unknown

External recon — discrepancy Open

Custody recon — Q2 Missing

A Resolution Pack You Couldn't Produce in 48 Hours

CASS 10 requires you to retrieve the resolution pack — the documents and records that let an insolvency practitioner return client money and assets fast — within 48 hours, with some items immediately. Most firms have the pieces scattered across systems. Assembling them on request, against the clock, is the test most fail.

48 hrs

To produce the full resolution pack on request.

"Where's Your CASS Audit Evidence?"

The annual CASS audit (SUP 3.10) tests classification, segregation, acknowledgement letters, reconciliations, the resolution pack and breach notifications. The auditor wants it assembled and current. Producing it from spreadsheets, in one sitting, is where the audit qualifications come from.

Client-bank acknowledgement letters · ?

Last external reconciliation · ?

Resolution pack retrievable · ?

If your client-money calculation lives in a spreadsheet, you can't prove your reconciliations were done on time, and you couldn't produce the resolution pack in 48 hours, the operating system below is for you.

Features

The CASS operating system your firm runs on.

Three things make it the operating system, not a spreadsheet. Nine capabilities turn it into the system your CASS oversight officer runs day to day — and when the FCA calls. One module covering every CASS chapter your firm is subject to — live, scored and evidenced.

Three ideas no spreadsheet CASS can match.

Most firms run client assets from a stack of spreadsheets and a folder of PDFs — until the FCA, an insolvency practitioner or the CASS auditor asks for proof. The operating system below is built on three principles that change what your CASS oversight officer can put in front of them.

Only the CASS chapters that bind your firm. Switched on automatically.

CASS is modular by firm type — no firm is subject to all of it. The CASS 1 applicability engine works out which chapters apply to your firm and switches off the rest, so you see the registers, calculators and evidence you actually need — and nothing you never will.

✗ Spreadsheets: the whole sourcebook, filtered by hand
✓ RegTechPRO: only your chapters, switched on by firm type

CASS 1 · Applicability engine

The CASS reports your auditor and Board expect.

Anna reads your live CASS data and drafts the reports — the CASS oversight report to the governing body, the resolution-pack master document, and your SUP 3.10 audit prep — with the citations and the numbers already in place. Not a blank template you fill in yourself.

✗ Other tools: a blank report template
✓ RegTechPRO: drafted from your live data, cited

Anna · SUP 3.10 prep

A Client Assets Health score out of 100 that can't be gamed.

The score is computed from your live data — pillar completion weighted across classification, client money, custody, reconciliations and the resolution pack, plus the CASS compliance checklist. Every point traces back to a record, so self-certification without evidence is impossible by design. RAG-rated green, amber or red.

✗ Other tools: tag complete, move on
✓ RegTechPRO: re-derived from data, defensible

Out of 100 · RAG-rated

Nine capabilities turn this into the system your firm runs client assets from.

Built for the daily client-money calculation, the reconciliation that won’t tie out, the resolution pack the FCA wants in 48 hours and the CASS audit due next quarter. Every capability ships in the module. No tier gate, no add-ons.

1 Classify & Safeguard Determine your CASS type, then safeguard client money and assets.

Firm classification & CASS oversight

The CASS 1A calculator works out whether you are a small, medium or large CASS firm — and your CMAR obligation — from your peak holdings, and records the CASS oversight officer (CASS 1A.3) and SM&CR mapping.

CASS 1A · Calculator

Client money — trust & segregation

Record the statutory-trust basis and segregation approach, with a register of every client bank account — acknowledgement-letter status, balances and bank concentration against the CASS 7.13.20R consideration.

CASS 7 · Client bank accounts

Safe custody assets & custodians

A register of safe custody assets by client and registration basis, plus custodians and sub-custodians with their due-diligence cadence and third-party-rights records (CASS 6.2 / 6.3).

CASS 6 · Custody

2 Calculate & Reconcile Run the calculations and reconciliations the rules demand — evidenced.

Client-money calculation

The built-in calculator computes your client-money requirement against your resource and tells you the exact top-up or withdrawal due by close of business — the CASS 7.16 calculation, done for you (CASS 7.15.29R).

CASS 7.16 · Calculator

Internal & external reconciliations

Reconciliation engines for client money and safe custody assets — log each internal record check and external reconciliation, flag discrepancies and shortfalls, and track them to resolution (CASS 6.6 / 7.15).

CASS 6.6 / 7.15 · Engines

Acknowledgement letters & breaches

A register of acknowledgement letters with countersignature status and review dates, and a breaches register with severity, FCA-notification status and remediation owners.

CASS 7.18 · Breaches

3 Resolve & Prove From live data to the resolution pack, the CASS audit and board-ready reports.

48-hour resolution pack

Every document and record the CASS 10 resolution pack must contain, each flagged for 48-hour or immediate retrieval, with a readiness gauge and a one-click master document an insolvency practitioner could act on.

CASS 10 · 48-hour

CASS audit prep & Health score

The CASS compliance checklist and gap analysis feed a Client Assets Health score out of 100, and assemble the evidence the annual CASS audit (SUP 3.10) tests — classification, reconciliations, letters, breaches and the resolution pack.

SUP 3.10 · Out of 100

Anna CASS reports & export

Anna drafts your CASS reports from live data — the oversight report to the governing body, the resolution-pack master document and SUP 3.10 audit prep — with citations and figures in place. Export to PDF, Word or CSV.

Anna · PDF/Word/CSV

Every CASS chapter your firm touches. One module.

An applicability engine switches on only the chapters that bind your firm. Six working surfaces feed a Client Assets Health score out of 100, and Anna drafts your CASS reports — including SUP 3.10 audit prep — from your live data.

CASS chapters covered

100

Health-score points

Hour resolution pack

Specialist regimes

SUP 3.10

CASS audit prep

Firm classification & CASS oversight CASS 1A

Client money: trust & segregation CASS 7

Client-money calculation & top-up CASS 7.16

Internal & external reconciliations CASS 6.6 / 7.15

Safe custody assets & custodian DD CASS 6

Acknowledgement letters CASS 7.18

Client-money distribution (pooling) CASS 7A

CASS resolution pack CASS 10

CMAR & the CASS audit SUP 16.14 / 3.10

Plus the specialist regimes: insurance client money (CASS 5) · debt management (CASS 11) · claims management (CASS 13) · payments & e-money safeguarding (CASS 15) · CFTC Part 30 (CASS 12) · temporary permissions (CASS 14) — plus the CASS compliance checklist with rule-cited tooltips, breach notifications to the FCA and bank-concentration monitoring.

Enterprise quality. SME pricing.

Affordable, modular monthly pricing · No tier gate. No add-ons. No setup fee.

See it in your firm

The Solution

Every CASS obligation. In one place.

Six working surfaces — dashboard, compliance checklist, calculators, registers, reconciliations and the resolution pack — feeding a transparent Client Assets Health score, every point auditable back to its evidence. An applicability engine switches on only the CASS chapters your firm is subject to, and Anna drafts your CASS reports and SUP 3.10 audit prep from your live data.

The whole client-asset position on one screen. A Client Assets Health score with a pillar-by-pillar profile, and live tiles for bank concentration, the client-money calculation, the custodian network, 48-hour resolution-pack readiness and a 12-month breach heat-map — every CASS obligation, RAG-rated, at a glance.

The FCA-minimum CASS controls your firm should be able to evidence — classification and oversight, client money and custody safeguarding, reconciliations, acknowledgement letters, the resolution pack, the CASS audit and breach notifications. Set each control Met / Partial / Not Met, with the evidence attached.

Built-in CASS calculators, not spreadsheets. The CASS 1A firm-classification calculator works out whether you are a small, medium or large CASS firm and your CMAR obligation; the client-money calculation computes requirement vs resource and the exact top-up or withdrawal due by close of business (CASS 7.15.29R).

Every CASS record as a structured register — client bank accounts with acknowledgement-letter status and bank concentration, custodians and sub-custodians with their due-diligence cadence, safe custody assets, mandates and collateral. The evidence an FCA visit or CASS auditor asks for, already assembled.

Internal and external reconciliation engines for client money and safe custody assets. Log each reconciliation, flag discrepancies and shortfalls, and track them to resolution — the records the CASS audit (SUP 3.10) is built on, kept current and exportable.

The CASS 10 resolution pack, mapped and retrievable. Every required document and record flagged for 48-hour or immediate retrieval, with a readiness gauge and a one-click master document an insolvency practitioner could act on — the pack the FCA expects you to produce within 48 hours.

The Anna Report Engine

The CASS reports you can rely on.

Board-ready CASS reports from one data set — the oversight report to your governing body, the resolution-pack master document and your SUP 3.10 audit prep. Built from your live registers, calculations and reconciliations, scored out of 100, signable as a PDF. Rehearse the CASS auditor’s questions before the audit does.

Full CASS Report

Oversight report
To the governing body

CASS Audit Dry-Run

Q&A · RAG-graded
Mock SUP 3.10 interview

Resolution Pack

Master document
48-hour index

Board Quarterly

Oversight pack
CASS 1A.3

Snapshot

One-page
Client-asset position

Live sample · Anna-drafted from real firm data

Anna sits as the CASS auditor.
Your CASS answers in its own voice.

Set CASS questions, each answered from your live data — the client-money calculation, reconciliations, acknowledgement letters, the resolution pack and breaches. RAG-graded. Examiner observation noted. Signable PDF in 60 seconds.

FCA / CASS Auditor How do you satisfy yourself that the money you hold for clients matches what your records say you owe them?

Anna Green · Met

The client-money calculation runs each business day under CASS 7.15 / 7.16 — the resource (cleared balances across the client bank accounts and qualifying money-market funds) reconciled against the requirement (the sum of individual client balances). Any shortfall is funded from the firm’s own money by close of business and any excess withdrawn (CASS 7.15.29R). For the latest calculation (5 Jun 2026) a resource of £4,200,000 equalled the requirement; the calculation, the segregated balances and the sign-off are all held against the date.

Examiner Observation The client-money calculation is performed daily, reconciled to segregated balances and evidenced to the day, with the CASS 7.15.29R top-up and withdrawal discipline in place. Meets the core CASS 7 client-money expectation.

FCA / CASS Auditor Show me your reconciliations — and what happens when one doesn’t tie out.

Anna Amber · Partial

Internal and external reconciliations run on the CASS 6.6 / 7.15 cadence — internal client-money and custody record checks, and external reconciliations to bank and custodian statements — each dated and signed off. On 28 Apr 2026 the external client-money reconciliation showed a £750 timing difference from a payment in transit at cut-off; it was investigated the same day, resolved the next business day, and recorded with no client-money shortfall. One custody reconciliation for Q2 is currently outstanding, on the forward plan for completion this week.

Examiner Observation Reconciliations are performed and discrepancies investigated and resolved without undue delay, with the audit trail intact. One outstanding custody reconciliation is an identified gap with a tracked completion date; the firm should clear it to return the cadence to fully current.

FCA / CASS Auditor If the firm failed tomorrow, could you produce your resolution pack within 48 hours?

Anna Green · Met

Yes. The CASS 10 resolution pack is mapped item by item, each flagged for 48-hour or immediate retrieval, with the location, owner and retrieval steps recorded. Readiness stands at 95% (21 of 22 applicable items in place and retrieval-tested), and the master document — the index an insolvency practitioner would work from — regenerates in one click from the live registers. The one outstanding item has a named owner and a target date.

Examiner Observation The resolution pack is mapped, retrieval-tested and current, with a one-click master document and the immediate-retrieval items (CASS 10.1.9E) identified. Demonstrates the CASS 10 48-hour expectation.

Every section. Every CASS anchor.

Anna drafts the CASS oversight report from your own live records — classification, client money, custody, reconciliations, acknowledgement letters, the resolution pack, breaches and the CASS audit. Scored out of 100 so a firm cannot claim 100% without the evidence trail to back it up.

CASS chapters covered

100

Health-score model

Hour resolution pack

~30s

To full draft

Firm Classification & CASS Oversight

CASS 1A

Client Money — Trust & Segregation

CASS 7

Client-Money Calculation

CASS 7.16

Client Bank Accounts & Diversification

CASS 7.13

Safe Custody Assets & Custodians

CASS 6

Reconciliations & Record Checks

CASS 6.6 / 7.15

Acknowledgement Letters

CASS 7.18

Client-Money Distribution (Pooling)

CASS 7A

Resolution Pack

CASS 10

Breaches & FCA Notifications

SUP 15

CMAR & the CASS Audit

SUP 16.14 / 3.10

CASS 6.6 / 7.15 · calculations & reconciliations

Dated calculations. Logged reconciliations. Resolved discrepancies.

A client-money calculation that runs but isn’t evidenced is the gap a CASS auditor qualifies. Every calculation and reconciliation here is dated, RAG-rated and reconciled; discrepancies become tracked actions with a named owner and a resolution date.

Owner	Calculation / reconciliation	Date	Outcome
Helena Ross CASS Oversight Officer	Client-money calculation: requirement £4,200,000 vs resource £4,200,000, individual-client-balance method (CASS 7.16). No top-up required.	Jun 05, 2026	Green · In agreement
Helena Ross Client Money Officer	External client-money reconciliation to bank statements. £750 timing difference from a payment in transit at cut-off.	Apr 28, 2026	Amber · resolved +1 day
Marcus Bell Head of Operations	Internal custody record check & external custodian reconciliation (Pershing) for all safe custody assets held.	May 31, 2026	Green · agreed
Helena Ross CASS Oversight Officer	Q2 internal custody reconciliation outstanding; scheduled and owned, completion due this week.	Pending	Red · due this week

Three named attestors. One oversight lifecycle.

SM&CR, proved. The CASS oversight officer owns the client-asset programme, the executive operates it, and the Board attests to the annual CASS oversight report (CASS 1A.3.1A). Once locked, the report stays traceable to the underlying registers, calculations and reconciliations, and reproducible for every CASS audit.

CASS Operational Oversight (CASS 1A.3)

Helena Ross

CASS Oversight Officer · Programme Owner

Signed Jun 06, 2026

SMF3 · Executive Director

Nadia Bergström

Finance Director · Client Assets

Signed Jun 07, 2026

Chair · Board Oversight

Reginald Bartholomew

Board Chair · CASS Sponsor

Signed Jun 08, 2026

Report locked · Jun 08, 2026 · 18:17 GMT Read-only. Traceable to every register, calculation and reconciliation. Reproducible for the annual CASS audit (SUP 3.10).

Anna AI for Client Money & Assets

Your full CASS report — and the audit dry-run — in 60 seconds.

Anna is trained on the CASS sourcebook — client money (CASS 7), custody (CASS 6), the resolution pack (CASS 10), reconciliations, acknowledgement letters and the CASS audit (SUP 3.10) — plus the specialist regimes. She answers your CASS queries in seconds, and drafts your choice of oversight report, resolution-pack master document, audit dry-run, Board Quarterly Pack or Snapshot — all from the live registers, calculations and reconciliations your firm has actually populated.

CASS EXPERT · SUP 3.10 PREP

Your CASS regulatory research desk and report author, in one.

Anna does two things for client assets. First, she answers any CASS query your team throws at her — rule-cited, handbook-grounded, with the specific figure from your own records where relevant. Second, she drafts your reports from the same data, sized for the audience: the CASS oversight report for the governing body, the resolution-pack master document for an insolvency practitioner, your SUP 3.10 audit prep, a Board Quarterly Pack and a one-page client-asset Snapshot. Speed via Anna AI, underpinned by 1,500+ expert documents.

Answers CASS 1A / 6 / 7 / 10 / 15 and SUP 3.10 queries with rule-level citations
Drafts your CASS reports from one data set — pick a format, Generate, done
Rehearses the CASS audit with green/amber/red answers and an examiner observation per question
Synthesises from your registers, calculations, reconciliations and resolution pack. Never invents defaults
Never attests for you. The oversight report and Board sign-off stay with the firm

Your CASS research desk

Ask Anna anything about CASS. Get a cited answer.

“When must we top up the client bank account?” “What must the resolution pack contain?” “How often must we run the external reconciliation?” Anna answers from the handbook, the CASS sourcebook and your live registers in seconds, with citations.

CASS 1A–15 & SUP 3.10 grounded
Cites rules, paragraphs & your own data
Reads your registers & CASS checklist live
Available across every CASS tab

Anna AI

Online · AI Compliance Advisor

When must we pay our own money into the client bank account, and is our process defensible?

Under CASS 7.15.29R, if your client-money resource is below your requirement at the calculation, you must pay the shortfall in from the firm’s own money by close of business that day; if it’s above, you may withdraw the excess. A defensible process is:

Segregate on receipt and run the calculation each business day (CASS 7.13 / 7.15)
Fund any shortfall the same day, before close of business
Record the calculation, the segregated balances and the transfer

Your latest calculation (5 Jun 2026) shows resource equal to requirement — no transfer needed. The prior day’s £1,500 shortfall was funded the same day, which is correct.

Drawn from: CASS 7.15.29R · CASS 7.13 · Your client-money calculation

Ask Anna anything about CASS…

→

Audit-ready the moment the regulator calls.

Anna drafts your CASS reports from the same live data in seconds — the governing body gets the oversight report, an insolvency practitioner gets the resolution-pack master document, the CASS auditor gets your SUP 3.10 prep, and you rehearse on the audit dry-run. When a reconciliation throws a discrepancy or the resolution pack drifts, the platform surfaces it and tracks it to a named owner. See it all in a live demo.

Book a live demo See everything Anna produces

FAQs

CASS, Questions Answered

Everything you need to know about CASS coverage, the Client Assets Health score, Anna's CASS report engine, the resolution pack and the CASS audit — and how it sits inside RegTechPRO.

What CASS reports does Anna produce?

From one data set: the CASS oversight report to the governing body (CASS 1A.3.1A), the resolution-pack master document an insolvency practitioner would work from, your SUP 3.10 audit-prep pack, a Board Quarterly Pack and a one-page client-asset Snapshot. You pick the format and hit Generate; all draw from the same live registers, calculations and reconciliations.

How does the Client Assets Health score out of 100 work?

Composite, out of 100. Your pillar statuses across classification, client money, custody, reconciliations, the resolution pack and breaches are weighted by importance (about 60%), and the CASS compliance checklist makes up the rest (about 40%). Pillar scores are derived from your live records, so a firm cannot mark itself 100% without the data behind it. RAG-rated: green ≥80, amber ≥50, red below — click the ring for the full breakdown.

Can we edit Anna's draft before it goes to the board or auditor?

Yes. Every section is editable inline, and Anna can regenerate any individual section when your underlying data changes. Export the report as a branded PDF (navy cover, auto-TOC) for the auditor or Board, or as a Word file that opens with track-changes for internal edits.

If I switch report formats do I lose the previous draft?

No. Each format keeps its own per-section cache. The Board Quarterly you generated in March is preserved when you switch to the full oversight report in April; switching back restores it exactly. Per-section regeneration only refreshes the section you click.

Which CASS chapters does the module cover?

The CASS sourcebook end to end — CASS 1A (classification & oversight), 3 (collateral), 5 (insurance), 6 (custody), 7 (client money), 7A (distribution), 8 (mandates), 9 (information to clients), 10 (resolution pack), 11 (debt management), 12 (CFTC Part 30), 13 (claims management), 14 (temporary permissions) and 15 (payments & e-money safeguarding) — plus the CASS audit (SUP 3.10).

I'm not subject to all of CASS. Do I have to wade through chapters I don't need?

No. CASS is modular by firm type, and so is the module. The CASS 1 applicability engine asks which activities your firm carries on and switches on only the chapters that bind you — the registers, calculators and evidence for those regimes — and suppresses the rest. An investment manager and a payments institution see two different, correct subsets.

How does the client-money calculation work?

The built-in calculator computes your client-money requirement (the sum of individual client balances) against your resource (segregated balances, QMMFs and transaction accounts) and tells you the exact transfer due under CASS 7.15.29R — pay any shortfall in from the firm's own money by close of business, or withdraw any excess. Run it as regularly as your firm requires, dated and evidenced each time.

What reconciliations and records does it support?

Internal and external reconciliations for both client money and safe custody assets (CASS 6.6 / 7.15), each logged with a date, result and sign-off. Discrepancies and shortfalls become tracked items resolved without undue delay — the evidence the CASS audit (SUP 3.10) is built on, kept current and exportable.

What's in the resolution pack, and can we really produce it in 48 hours?

Every document and record CASS 10 requires, mapped to its location, owner and retrieval steps, and flagged for 48-hour or immediate (CASS 10.1.9E) retrieval. A readiness gauge shows how close you are, and a one-click master document — the index an insolvency practitioner would work from — regenerates from your live registers. Producing the pack stops being a scramble.

Does it handle the specialist regimes?

Yes — insurance client money (CASS 5), debt management (CASS 11), claims management (CASS 13), payments & e-money safeguarding (CASS 15), CFTC Part 30 (CASS 12) and the temporary permissions regime (CASS 14) each have their own surface, switched on by the applicability engine when they apply.

How much does the CASS module cost?

Affordable, modular monthly pricing. See regtechpro.co.uk/pricing for the full modular calculator — start with the free foundation and add the modules your firm needs.

Do I need the whole RegTechPRO platform, or can I just have this module?

The CASS module is an add-on to a RegTechPRO subscription. It sits inside the platform so it can share data with People Compliance, the Document Library evidence vault and Anna. Every subscription includes the free foundation — Document Library, Horizon Scanning, Media Hub, Anna AI and unlimited users.

How long does setup take?

Under a day. The module ships pre-seeded with the CASS compliance checklist, the gap-analysis structure, the firm-classification and client-money calculators, the register templates and the resolution-pack contents list. You complete the firm profile, the applicability engine tailors the chapters, and you populate your registers. No migration project — the framework ships built in.

Can I run it across more than one firm or entity?

Yes. Each firm or entity gets its own isolated workspace — its own registers, its own Client Assets Health score and its own oversight report — with unlimited workflows on every subscription. Data never crosses between workspaces.

Does Anna ever attest on my behalf?

No. Anna synthesises; she never attests. Human attestation at the input (your classification, your reconciliations, your sign-offs), AI efficiency in the middle (the drafted report), human sign-off at the output (the CASS oversight report to the governing body, CASS 1A.3.1A). The supervisory-grade division of labour the FCA expects to see.

What does Anna actually cite when she writes?

The CASS rule she's addressing — for example the client-money chapter opens on CASS 7.15 / 7.16 and the resolution-pack chapter on CASS 10.1.7R — plus the specific facts from your records: the calculation figures, the reconciliation dates, the acknowledgement-letter status, the resolution-pack readiness. Cited rules, your data, no invented defaults.

How is multi-year history kept defensible?

Previous years auto-lock and become read-only, so a CASS auditor opening the prior year sees exactly what was approved at the time. A legitimate amendment requires an audited unlock that captures your email and a required reason, both written to the audit trail. Defensible posture for any FCA or audit review.

What audit trail does the CASS auditor see?

Every pillar status is timestamped. Every reconciliation and client-money calculation records a date, result and sign-off. Every breach carries a severity and FCA-notification status. Every resolution-pack item records its retrieval test and owner. An auditor asking “when did you last reconcile, and what happened to that discrepancy?” gets a dated, named-owner answer in one click.

The Client Money & Assets operating systemyour firm needs.