PwC has identified the requirement for a ‘single director or a senior manager of sufficient skill and authority’ to be dedicated to CASS oversight (having no other responsibilities) as the CASS change causing the biggest stir from the FCA’s recently released MiFID II policy statement PS17/14.
PwC’s previous research has shown that Senior Managers responsible for CASS spend as little as 5% of their time on CASS. Many will hope that they can continue without a dedicated CASS oversight manager by closely considering the FCA’s wording, “unless the firm is satisfied on reasonable grounds that…the director will still be able to discharge the CASS oversight responsibilities effectively. Given the continued focus on effective CASS oversight by the regulators, PwC suggests clients:
“Recognise the importance of innovation and technology-enabled solutions to effectively manage and delegate their CASS oversight responsibilities, whether this is around using the vast amount of data at your fingertips to have more insight into compliance, gaining more insight through MI, finding better ways to monitor your use of third parties, etc.”
AutoRek offers such a CASS solution, so, of course we agree!
AutoRek is a data governance platform which includes automation of internal and external reconciliations, execution of the daily client money calculation, identification and treatment of shortfalls, production of CMAR and support for CASS RP. To find out more download our complimentary whitepaper; FRC and the new CASS Audit Regime: Systems, Controls and Reconciliations.