The introduction of the CASS 11 – Debt Management chapter into the FCA CASS Handbook brought many Debt Management firms under the CASS banner. These firms now face greater regulatory, data management and controls framework scrutiny.
Many firms struggle to comply and apply best practice to their client money identification, segregation and protection responsibilities. Common issues include:
• Discharge of fiduciary duty (11.4)
• Failure to allocate client money in a timely manner (11.9.7)
• Failure to maintain accurate internal records differentiating the client money held for one client from any other client (11.11)
• Failure to maintain an internal record of funds held in client money segregated bank accounts (11.11.2)
• Client Money methodology – identification of negative client balances (11.11.22)
This paper take a closer look at the FCA's CASS 11 requirements and highlights how some of the key features of AutoRek's data governance platform can help.
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