Good governance is vital for compliance with CASS regulations, demonstrating suitable oversight of a firm’s internal systems and controls. One of many challenges facing firms is building a culture that promotes change and innovation, while also ensuring that governance processes adhere to regulations and prioritise the client’s best interests. The FCA frequently discusses these two…

The FCA has placed greater emphasis on Operational Resilience over the past few years to ensure firms can withstand disruption and absorb shocks while still delivering key services. The regulator published a consultation paper on building Operational Resilience – CP19/32 – in December 2019. And, after multiple consultations, the final rules eventually came into effect…

CASS audits have changed over the past few years. They have shifted from substantive sample testing methods to a more control-based approach. This is widely considered more proactive because it challenges the suitability of critical controls underpinning a firm’s operational process. In past instances of CASS breaches – or where control has proved weak and…

Under CASS rules, firms must implement the systems and controls required to meet obligations and maintain accurate records and accounts. This is particularly important in relation to safe custody assets held for clients. And recently, the regulator’s expectations for record-keeping and retention have become even greater. This is to ensure that controls are in place…