Services

Client Assets CASS

Risk Advisory

Our dedicated CASS Risk Advisory team are passionate about supporting firms to understand the practical application of the CASS rules. We work with a wide range of financial institutions providing a variety of advisory services ranging from CASS SMF/oversight mentoring to full scope assessments of firms’ CASS control environments.

Our CASS specialists are skilled at supporting firms with interpreting the CASS rules and the development of a CASS control environment that is fit for purpose and that will withstand external scrutiny.

We take a collaborative approach on all of our CASS engagements to ensure that we agree factual accuracy of any findings during the course of our engagement and raise any potential issues or areas of non-compliance as soon as we identify them, so that we can support you in developing proposed remedial action during the course of our engagement.

There are a number of business scenarios where we can provide our Risk Advisory services and the following are examples of the types of scenarios and activities that we cover:

  • CASS SMF/ Oversight support
    • Preparation for FCA authorisation including mock interviews and personal development programmes;
    • Ongoing support relationships, industry intelligence and regulatory insight.
  • Ad-hoc advice and training
    An ‘on-call’ service that clients use to source:
    • Technical CASS input;
    • Insight ahead of new products and business change decisions;
    • Advice on relationship with FCA
    • Bespoke CASS operational and board training.
    • CASS Academy
  • FCA Regulatory Visits and Review
    Conduct a “dress rehearsal”, this can include:
    • Detailed walk through of the firm’s key CASS reconciliation processes;
    • Mock interviews for key reconciliation and CASS governance personnel;
    • Readiness training for executives and senior CASS personnel.
  • Audit Findings and Remediation
    • Conduct a series of workshops to develop a clear plan of activities to support timely remediation of CASS audit findings;
    • Provide guidance and support in the development of a full suite of CASS governance policies.
  • Risk and Control Management
    • Provide support for the detailed mapping of CASS rules to the firm’s risks and controls;
    • Develop a framework for the ongoing monitoring and assessing CASS controls.
    • RegHub – our proprietary CASS risk assessment tool.
  • Business and Regulatory Changes
    Support the firm to understand the impact of changes on the CASS control environment. Changes can be a result of New Regulations, New Products, Business Acquisition, Disposal and Consolidation, System Change and Migration or Out-sourcing and In-sourcing
    • For proposed new business acquisitions, review the due diligence work to provide a view on CASS risks and/or remediation
    • Review existing operating models and make recommendations for a target model that will comply with the regulations.
    • Provide support on incorporating the changes within governance and oversight framework.
    • Work alongside the firm to implement changes to the CASS operating model.
  • CASS resources
    Provide CASS subject matter experts for a specific period:
    • To support the Compliance team with day to day monitoring and support of business operations
    • To support the Internal Audit team with specific CASS audits
    • To support the CASS Oversight team with its daily oversight and make recommendations to enhance the oversight framework.

Our CASS team understands the need for firms to develop their own people so that in-house CASS skills capabilities are deepened. We ensure that during our engagement we seek out opportunities to transfer our CASS knowledge and expertise to the relevant team, either during the course of the engagement through collaborative working or through formal training and knowledge transfer sessions.

CASS Risk Advisory Team credentials

Many of Deloitte’s Risk Advisory SMEs have a regulatory background, allowing us to provide our clients with a direct insight into the FCA’s and PRA’s expectations on authorised firms, and to give valuable context behind the regulator’s approach. Drew has 10 years of experience working in regulatory supervision at the FSA and FCA, including several years as the lead associate within the FCA’s specialist CASS supervision department. We are also able to provide support from former FCA Prudential supervision specialists, Conduct supervisors and individuals with direct experience within the FCA’s authorisations department

Our team includes experienced external CASS auditors. This is a very important aspect of our experience as it enables us to bring auditor level scrutiny to the assessment of CASS control environments and to share learnings from firms that have faced a variety of CASS challenges. Anna leads CASS audits for a number of medium and large platform firms.

We have experience in providing in-depth reviews and internal audit and compliance support for vital CASS areas in the asset management sector. Often, these areas require both expert technical knowledge and an awareness of industry practice – current hot topics include:

  • CASS Governance and Culture;
  •  Records, timing and accuracy – settlement models;
  • Prudent segregation – policy and audit records;
  • Reconciliations – pre-funding and shortfalls;
  • TPA monitoring framework – MI, data analysis;
  • TPA breach investigation – framework and reliability;
  • TPA oversight – contracts, conflicts of interest, risk management, and
  • CASS resolution packs

Key contacts

Nikki Lovejoy

Nikki Lovejoy

Partner

Nikki Lovejoy has 20 years of financial services and consultancy experience. She specialises in providing regulatory consulting services to banks, investment, and consumer credit firms. She has extens... More

Anna Dawson

Anna Dawson

Director

Anna is a chartered accountant with over 27 years of experience working in the financial services industry. She is a dedicated CASS specialist and leads Deloitte’s risk advisory CASS engagements. She ... More

Mustafa Kanchwala

Mustafa Kanchwala

Senior Manager

Mustafa Kanchwala joined Deloitte’s Risk Advisory practice having held the position of CF10A (Client Asset Oversight Function) and CF11 (MLRO) for investment trading firms previously. Mustafa has a br... More

Drew Franks

Drew Franks

Senior Manager

Drew Franks has over fifteen years of experience working with major financial firms and the UK regulator. Drew was a lead associate at the FCA’s CASS specialist department FCA bringing with him 10 yea... More