Stories of our impact
A new tool for CASS rules
In the world of compliance advisory, CASS rules (standing for Client Money and Assets Sourcebook) govern how investment firms protect their clients’ money and assets. Some CASS-regulated firms have struggled to comply with the rules in practice, and in recent years the Financial Conduct Authority (FCA) has levied substantial fines for CASS breaches.
When the Financial Reporting Council (FRC) did a major overhaul of CASS rules for auditors in November 2015, regulated firms also faced a considerable challenge. They needed to maintain an extensive risk assessment of their CASS controls and procedures from 1 January 2016 to satisfy the requirements of their auditors. But how could they appropriately structure the initial CASS risk assessment process and perform this risk and control mapping exercise? And how would they maintain it going forward?
As a leader in both regulatory advice and technology delivery, we wanted to make sure our clients understood the new requirements and were able to demonstrate they had an appropriately documented risk and control assessment methodology in place. Here’s how a team in our Risk Advisory business moved our advisory clients away from onerous spreadsheet analysis by developing an integrated online solution that has received industry-wide recognition.
Hello online application
Anna Dawson in our Risk Advisory team knew through her work as a CASS auditor and advisory specialist that the incoming requirement would be a difficult ask for CASS firms of all sizes. Spotting a gap in the market, she developed an application that would not only simplify the process for our clients but also provide valuable information at the touch of a button.
She worked with colleagues in Risk Analytics and fellow CASS specialists within Deloitte to expand our PROACT platform (a cloud-based application helping firms to navigate, record and track their regulatory obligations in a single place) and develop a risk assessment module designed to support her advisory clients in meeting the new FRC standards.
Bye bye spreadsheet
So how does it work? The tool contains all the FCA’s CASS rules and provides a simple, logical structure to help firms to develop and maintain a CASS risk assessment in a way that can be easily replicated across legal entities - enabling a consistent approach across often complex business structures. The application went live during November 2016 and has received excellent feedback from advisory clients.
Replacing an onerous set of processes that were often undertaken in an Excel spreadsheet, the tool Anna and her team developed offers a simple, web-based solution that makes it easy for firms to comply with, and maintain, risk assessments. Several advisory clients have now bought licences for the application, with users saying that it is simple and intuitive to use.
Not only has the tool been recognised across the industry for helping to address a particularly challenging CASS requirement, it is also a great platform to further develop our range of compliance solutions that will help our advisory clients to improve their CASS compliance processes – and beyond.