CASS and Safeguarding Capability
(a) Develop enhanced management information (b) To oversee the firm’s Operations team in their work to resolve historic unresolved differences
(a) complete a gap analysis of current arrangements against the CASS reporting requirements (b) develop a framework and project plan for reporting
The key complexities were (a) new and untested regulatory requirements (b) the difficulties in retrieving customer records from over ten years
We were engaged by a Global Asset manager to help them remediate their client asset management.
The project objectives were to (a) develop enhanced management information to comply with FSA’s new CASS reporting requirements and (b) to oversee the firm’s Operations team in their work to resolve historic unresolved differences on the client money bank account reconciliations.
Our approach was to (a) complete a gap analysis of current arrangements against the CASS reporting requirements and develop a framework and project plan for reporting. We then increased awareness within the firm providing guidance and input into the customer contact process and (b) to meet regularly with the senior management of the Operations team to review management information and to review detailed working papers and reconciliations. Oral progress reports were provided to the Head of UK Compliance as the work progressed and a final report prepared for use by the Head of UK Compliance.
The key complexities were (a) new and untested regulatory requirements and the use of third party administrators whose business process models rely on consistency across all its clients and (b) the difficulties in retrieving customer records from over ten years previously and under previous management in order to resolve the longstanding historical unexplained differences. There was further complexity in that there was an ongoing customer contact programme that required close tracking to ensure there were no fraudulent claims or mis-use of client money. Further complexity arose as it emerged that the operations team dealing with the project had been historically responsible for the oversight of the client money administered by the third party. The Protiviti team assumed responsibility as second line of defence to ensure that issues were demonstrably satisfactorily resolved and documented as well as root cause understood and where appropriate amended policies, procedures and processes put in place with relevant training.