Our Client Asset Sourcebook (CASS) controls expertise

Bringing together the expertise of our FS focussed senior colleagues, our team has unrivalled experience working with regulated firms. Our dedicated FS team is headed by Managing Director Dina Devalia, an FS sector specialist who works exclusively with regulated businesses. Dina is both a licensed and qualified restructuring professional, as well as a leading regulatory specialist, having spent ten years of her career at the Financial Services Authority (predecessor to the FCA). Since 2012, Dina has specialised in advising FS firms when facing challenging trading conditions, insolvency and regulatory issues.

Client Asset Sourcebook (CASS) controls

If your business goes down, failure to segregate clients’ assets could leave clients/consumers seriously out of pocket. But poor systems, oversight and control, combined with a lack of proper documentation, heighten the inherent risk facing CASS firms and their senior management team, which could result in regulatory sanctions and/or insolvency.

Payment services firms can help shape the funds safeguarding regulations in the proposed new Client Assets Sourcebook chapter (CASS 15) to deal with the implications and deliver value to the business.

Firms should not underestimate the CASS risks and what it takes to assure the FCA that safeguards for client and custodian assets are up to scratch. It is important to deal with any deficiencies promptly and ensure that proper systems and controls are in place to document the action taken.

With your board in the direct firing line, the resulting fallout from CASS deficiencies could include protracted litigation, stiff regulatory penalties, insolvency and career-threatening reputational damage. But get this right, and CASS can not only bolster your credibility with the FCA with regards to the safeguarding, but it can also enhance your brand.

Depth of experience

We have expertise in assisting FS firms facing challenging trading conditions or insolvency and regulatory issues including CASS Rules, capital requirements, Senior Managers Regime, Single Customer View (SCV) file preparation, Wind-Down Planning (WDP) and Solvent Exits. We are known for our ability to deliver results, which are often achieved under the most challenging of circumstances, including:

  • Cashflow difficulties
  • Creditor pressure
  • Working capital shortfalls
  • Adverse trading conditions
  • Fraud

Senior specialists to support you

Our multi-disciplinary team of senior specialists blends a strong background in financial advisory, restructuring, special situations and regulatory expertise to deliver actionable results. We complement this with unrivalled experience in working with the key regulatory stakeholders in respect of regulated businesses.

Here to help

We can advise on how to deal with any inherent risks posed with the failure of safeguarding client assets. This includes support with drawing up wind-down plans and assistance with resolution packs. It also includes looking at the wider implications of the proposed FCA consultation in respect of CASS 15 and in the prospect of earlier FCA intervention and heightened insolvency risks.

If you would like to know more about CASS controls or how we can help, please get in touch.
 
 

Dina Devalia
Managing Director
T: +44 (0)20 3872 8342
M: +44 (0)7557 419 361
E: dina.devalia@quantuma.com

 

 

Brian Burke
Managing Director
T: +44 (0)20 3856 6720
M: +44 (0)7464 545 265
E: brian.burke@quantuma.com

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05 March 2024
FCA reminds Financial Services firms of the importance of preparing a wind-down plan
Author: Paula Fagan, Marketing Manager

As part of its latest key updates, the Financial Conduct Authority (FCA) has published guidance for Financial Services (FS) firms on preparing a wind-down plan. The purpose of a wind-down plan is to enable a FS firm to cease its regulated activities and exit the market in an orderly manner, if its business is no longer viable. The FCA states that it: ‘expects firms to consider the scenarios leading to financial stress, explore recovery options and, as a last resort, wind-down their business’.

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12 February 2024
Dangers of complacency: Are your Client Asset Sourcebook (CASS) controls really as watertight as they should be?
How financial services firms can gain confidence in CASS compliance.

If your business goes down, failure to segregate clients’ assets could leave clients/consumers seriously out of pocket. But poor systems, oversight and control, combined with a lack of proper documentation, mean that many financial services (FS) firms are falling short of their CASS obligations and leaving their senior management team at risk of severe regulatory sanctions.

Dina Devalia looks at why CASS should be front and centre of the boardroom agenda and how to gain real confidence that your client money safeguards are fit for purpose.

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06 December 2023
Prepared for the worst: How to turn wind-down planning into a source of strength
Savvy planning tips for financial services firms.

The Financial Conduct Authority (FCA) is turning up the spotlight on what it sees as “widespread weakness in wind-down planning”. If your wind down planning (WDP) fails to meet the FCA’s expectations, your firm could face an increase in regulatory scrutiny on capital and operational controls. But as Dina Devalia explains, effective wind-down planning isn’t just a compliance exercise. It’s also a good way to test the viability of your operations. So how can you get your wind-down planning up to the mark?