An impact of the recent Client Assets (CASS) rule changes was undocumented in the cost benefit analysis and, reportedly, was unexpected even for the regulator. Its effects may dwarf that of the restriction of the fund manager's DVP exemption, to which so many column inches and hours of industry debate have been devoted.
The impact is the outcome of the strict application of the need to hold sufficient cash at all times, including intra-day, to meet all clients' entitlements.
The consequential cost of this tightening of the rules has been significant for many firms. So what is the requirement, exactly, and why is it such a painful change?
Intra-Day Client Money Management
In alliance with specialist CASS consultants Walbrook Partners, this intra-day client money whitepaper explores both the FCA's defined requirements (the "Known Knowns") and undocumented features (the "Unknown Unknowns") of the recent CASS rule changes, including:
- Known FCA Requirements as Encapsulated in CASS 7.12 and CASS 7.17
- Examples of Situations where Intra-Day Shortfalls are Certain to Arise
- The Practical Issues to be Addressed in Implementing the Requirements
- Approaches to Reducing the Burden (Managing the Unknowns)
- Contacting Walbrook Partners to Help Navigate your Intra-Day Funding Unknowns
- Using AutoRek's Client Money Solution to Perform Intra-Day Reconciliations
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