• Search in Protiviti.com

Client Assets (CASS) and Safeguarding

Client Assets (CASS) and Safeguarding

MiFID Firms that hold client’s money or assets and Payment / E-money Firms must segregate the assets, monies and relevant funds of clients such that in the event of an insolvency, those monies, assets and relevant funds are clearly identifiable as belonging to clients and avoid being placed into the pot of assets available to general creditors.

Protiviti provides Client Assets and Safeguarding advice and guidance via review of clients’ systems and controls and governance arrangements. We assess compliance with relevant regulations, guidelines and best practice. Protiviti is on the S166 panel for client assets and also performs annual, independent assurance reviews of safeguarding  arrangements. In these reviews we often use our own CASS and Safeguarding capability maturity model to help make these assessments and to show clients where and how to improve. We have developed an experienced and diverse team with the 1st, 2nd, and 3rd line experience.

The rules that we focus on are the FCA handbook ‘CASS’ and  MIFID2. For payment and e-money firms our focus is on the Payment Services Regulations 2017 and the Electronic Money Regulations 2011 plus the FCA’s guidance in ‘Payment Services and Electronic Money our Approach’.

Client Assets (CASS) and Safeguarding

CASS is a complex regulation requiring knowledge of insolvency arrangements, a deep understanding of business processes as well as a detailed knowledge of regulations and best practice. Protiviti offerings include, but are not limited to:

  • Performance of Compliance testing over the CASS framework
  • Section 166 - Protiviti have been appointed to the Skilled Person Panel for Client Assets
  • Internal Audit
  • CASS Training
  • Preparation for CASS external audit and post-audit remediation

Safeguarding regulations require payment and e-money firms to protect and segregate client funds.

Safeguarding requirements are becoming more rigorous. The FCA is consulting on rules that will lift safeguarding compliance to a similar level of precision as CASS. At the same time, auditors continue to raise standards as they and the firms they review improve their understanding of the safeguarding requirements.  Protiviti helps offers the following services to clients:

  • Annual, independent assurance review of safeguarding arrangements
  • Safeguarding audit preparation (health check) and post-audit remediation
  • S166 reviews
  • Review/implementation of the safeguarding frameworks
  • Safeguarding training
  • Controls review
  • Preparing firms for the proposed new rules per consultation paper CP24/20

Our approach to external independent safeguarding reviews under the guidance as it currently stands is to perform a reasonable assurance review in accordance with ISAE3000.  Our reviews consist of documentation review, interviews and sample testing and are typically completed in under a month. Findings raised are carefully and clearly explained to clients allowing clients to create accurate remediation plans.

Protiviti offers payment and e-money firms a full suite of consulting services including anti financial crime, control enhancements, SCA-RTS and PCI reviews. We are proud to have a strong list of top tier payment firms to whom we provide our services.

Loading...