A firm must arrange adequate protection for clients' assets when it is responsible for them. Principle 10 of the regulator’s Principles has been sorely tested by the recent failures of large institutions and the resultant chaos in trying to identify and distribute appropriately Clients’ Assets which had been caught up...
A firm must arrange adequate protection for clients' assets when it is responsible for them. Principle 10 of the regulator’s Principles has been sorely tested by the recent failures of large institutions and the resultant chaos in trying to identify and distribute appropriately Clients’ Assets which had been caught up in the collapse.
As a result, the Client Asset Rules, found in the CASS chapter of the regulator's handbook, include the requirement for firms to allocate responsibility for oversight of the firm’s operational compliance with CASS and (other than CASS small firms) allocate the CF10a CASS Operational Oversight function to a Director or Senior Manager. It is of paramount importance those firms with a Client Money and/or Client Asset role, and the individuals who have been given the CF10a tasks, understand fully what it is the regulator is trying to achieve and the responsibilities that go with it all.
Who is this for?
This course has been designed for those holding Controlled Function CF10a CASS Operational Oversight and individuals in all firms who are involved in, or responsible for, the safe custody of Assets and holding Client Money.
Background and purpose of CASS
- Cases which have shaped the Rules
The regulator’s stance – SYSC and the Approved Persons regime
- Why has the CF10a role been created?
- The CF10a role & the scope of the Rules: Responsibility or Oversight?
- Systems and controls for CF10a
- Reporting responsibilities
- Relations with regulators and auditors
Specific aspects of CASS
- Client Money calculations and reconciliations
- Segregation of accounts and relevant documentation
- Paying interest
- Types of Client Money accounts
- The 'Alternative Approach'
- Approved banks
CASS Resolution Pack
- Disaster Recovery planning
After attending this course, you will be able to:
- Describe the role and responsibilities of the CF10a CASS Operational Oversight function
- Assess the impact of these responsibilities on current corporate governance arrangements in your firm
- Benchmark your current policies and procedures against best practice
- Identify changes that need to be made to your firm's current arrangements to enable compliance with new obligations under the Client Asset Rules, including ‘Resolution’ arrangements