CASS Resolution Pack Contents

Posted on by Know Your Compliance
CASS Resolution Pack Contents
05
Oct

Introduction to the Client Asset Sourcebook (CASS)

Where certain regulated firms hold or control client money or safe custody assets as part of their business, they are required to comply with the FCA’s Client Assets Sourcebook (CASS) rules. The guidance, rules and requirements set out in CASS have been created to ensure that adequate protections and controls are in place to safeguard client assets should a firm fail and/or exit the market.

CASS RP PackClient Assets is an area of high importance to the FCA. The regulator has made significant changes to this area since taking over the regulatory role. The aim of the CASS rules is not only to protect a clients’ money and assets, but to build and maintain their confidence in the financial markets.

FCA Principle 10 Clients’ Assets – “A firm must arrange adequate protection for clients’ assets when it is responsible for them”.

CASS Classification

Ensuring that a firm knows which CASS type they are at any given time is a regulatory requirement. The firm type must be reported to the FCA on an annual basis based on the criteria set out in CASS 1A.2.7. Where a firm is near the upper limits of a firm type, they can opt to be treated as being in the next category up.

Which rules and requirements a firm must follow under CASS is dependant on the firm type they define as. Under the CASS system, a firm holding or controlling client assets will fall into one of three firm types:-

CASS Firm Type

Highest total amount of client money held during the firm’s last calendar year

Highest total value of safe custody assets held by the firm during the firm’s last calendar year

Large Firm

More than £1 billion

More than £100 billion

Medium Firm

An amount = or > £1 million & < or = £1 billion

An amount = or > £10 million and < or = £100 billion

Small Firm

Less than £1 million

Less than £10 million

CASS Notifications & Returns

There are a number of returns and notifications a firm is required to submit if they have obligations under CASS. Such reports and returns must be completed within set regulated timeframes by the person with responsibility for the CASS Oversight Function (CF10a or SMF18).

Reports, returns and notifications completed in relation to CASS are: –

  • The CASS classification questionnaire, completed annually within 15 working days of 31 December.
  • On or before the fifteenth business day of January: –
    • CASS firm type classification.
    • Any client money or safe custody assets held by the firm in the previous calendar year.
    • The highest total amount of client money and the highest total value of safe custody assets held during the previous calendar year.

Client Assets Resolution Pack

CASS Resolution Pack TemplatesThe CASS Resolution Pack (CASS RP) is a collection of records and documents that are required to comply with the FCA’s client assets regulations and rules. Where a firm holds client money and/or safe custody assets, it is obligated to have a resolution pack in place. This pack must include a master document that provides easy and quick access to the location of necessary documents and information.

A CASS Resolution Pack is designed to be a readily available tool that assists the firm and its staff. However, the primary function is for it to be available if requested by any of the below bodies: –

  • The Financial Conduct Authority (FCA).
  • An Insolvency Practitioner.
  • An Administrator.
  • A Receiver.
  • A Trustee.
  • A Liquidator or an analogous officer appointed in respect of it.

The Master Document notes the location, retrieval deadline and last review date of each mandatory document in the CASS Resolution Pack (RP). There are more than 20 documents and records needed to complete the CASS resolution pack requirements. These include, but are not limited to: –

  • Master document containing information sufficient to retrieve each document in the firm’s CASS resolution pack.
  • A document identifying the institutions the firm has appointed for the placement of money, to hold client money and for the deposit of safe custody assets.
  • A document identifying each AR, tied agent, field representative or other agent of the firm which receives client money or safe custody assets in its capacity as the firm’s agent.
  • A document identifying each senior manager, director or other individual responsible for the performance of any CASS obligation or operational function.
  • A document identifying the person who has been given the responsibility for CASS operational oversight.
  • A copy of each executed agreement for each institution identified.
  • A copy of any written notification or acknowledgement letters sent or received to/from each institution identified.
  • A document identifying each member of the firm’s group or any third party used by the firm, who are involved in operational functions.
  • A copy of each executed agreement between the firm and each third party.
  • A document describing how to gain access to relevant information held by each third party and how to effect a transfer of any of the client money or safe custody assets held by the firm but controlled by that third party.
  • A copy of any agreement entered into with the client under COBS 3.8

CASS Resolution Pack Manual & Templates

CASS Manual & Resolution Pack ToolkitOur exclusive CASS Policy Templates & Resolution Pack will help you to comply with the FCA’s Client Assets (CASS) Sourcebook. Ready to use templates and records for handling client monies and assets.

Covering both CASS 10 and CASS 11 requirements, the pack includes a compliant CASS Resolution Pack and Master Document template for just £65 (exc vat)

Read More about our CASS Resolution Pack NOw!