Automated client money reconciliations help UK firms meet FCA requirements for early attestation.
What Is Automated Client Money Reconciliation?
One of our Investment Management clients came to us with a problem; their teams used to log on at 08:30 and finish yesterday’s work. Teams faced long exception lists, tight cutoffs, and management information (MI) did not highlight true client money risks. As their business grew beyond a CASS Medium firm these issues increased.
The brief to the team at Leaman Crellin was simple: Make the daily cycle ready for attestation before 08:30 and keep the core stack. We led the CASS design and worked alongside the client’s chosen RegTech to automate ingestion, matching and the attestation pack. We set tolerances, an exception policy and clear gating checks, and ensured the evidence stands up to CASS Oversight, audit and the Client Money and Assets Return (CMAR).
Bank statements now arrive automatically via SFTP, SWIFT MT940/942, host to host connectivity, and APIs where available. The prior day ledger is frozen. Files are validated and everything is normalised into a single cash schema, so the overnight run completes cleanly. Automated client money reconciliations have ensured this client is now compliant.
Under CASS 7 the automation performs the daily client money calculation, comparing client money resource and requirement. It then runs the internal client money reconciliation and the external reconciliation to client bank accounts, covering general client bank accounts and, where used, designated client bank accounts. Breaks are classified by root cause, aged with service level agreements (SLAs), and controlled with maker checker approvals and role-based access control (RBAC).
Steps for FCA Attestation – What’s Required Before 08:30
What does ready for attestation before 08:30 mean in practice? The system has completed the client money calculation and both reconciliations. The evidence pack and MI are produced, and all gating checks are green. CASS Oversight reviews and attests in minutes. Non-gating items include timing differences or narrative mismatches within tolerance; they are owned with SLAs and cleared during the day and no longer block the morning.
Benefits of Early Reconciliation for UK Firms
The difference shows up first thing. The client money position is ready before teams log on. There is headroom for top-ups, less pressure around cutoffs, and less need for prudent over segregation. Exception queues are shorter and easier to prioritise. Conversations with Risk, Compliance and Internal Audit are calmer because controls are consistent, reproducible and well evidenced. Every run captures inputs, rules, approvals and outcomes; is traceable to CMAR; and is referenced in the CASS Resolution Pack so records are easy to locate. We also update procedures and train BAU teams, so the new control runs the same way every day.
“We start the day with a clean position. The client money calculation and reconciliations are ready before 08:30 and the MI shows true client money risk rather than noise.” Head of CASS Oversight, UK investment manager
If your reconciliations still rely on spreadsheets, book a discreet CASS 7 health check to discover how automated client money reconciliations can help your CASS compliance. We are vendor neutral. Outcomes are subject to data availability and statement timings. All conversations are confidential and anonymised by default.
See our six FCA CASS safeguarding compliance tips Top Six FCA CASS Safeguarding Compliance Tips for 2025/26
