As defined in the handbook CASS 6.6.54R applies where a firm identifies a discrepancy as a result of, or that reveals, a shortfall, which the firm has not yet resolved. A firm must keep a record of the shortfall description, underlying clients impacted, actions taken to resolve and the amount of money or assets the firm has segregated to protect impacted clients.
Ensuring compliance to CASS 6.6.54R continues to prove a significant challenge to FCA CASS regulated firms. For most firms, the constituent parts exist, but the disparate data feeds, operational BAU crossover and manual processing expose firms to unnecessary risk and more importantly, unnecessary risk to a firm’s underlying clients.
Achieving CASS Compliance
This paper highlights the requirements and common challenges of CASS 6.6.54R with particular emphasis on the identification and treatment. This paper also explains how AutoRek helps firms to fully understand and make the most of their data from a reporting capability.
By implementing a robust, automated financial control regime, firms will ensure ongoing compliance with Client Asset rules and regulations.
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