1. Master the CASS Fundamentals First
- Review CASS arrangements against the core principle: client assets must be kept safe, segregated, and protected
- Train staff to understand their responsibilities
- Document processes clearly for regulators
Training: CASS for Beginners at leamancrellin.co.uk covers regulatory requirements, best practices, and lessons from past failures.
2. Understand What Regulators Look For
- Demonstrate real-time visibility of client asset positions
- Show how you identify and resolve CASS breaches quickly
- Provide management information that gives the complete picture
Training: CASS Support Functions course helps teams understand three lines of defence and develop monitoring tools.
3. Address Common Compliance Pitfalls
- Carry out daily reconciliations on all reconciliation days (excluding weekends, UK bank holidays, and relevant foreign market closures under CASS 15)
- Resolve unclear bank segregation arrangements
- Review dormant client asset procedures
Training: CASS Operations course provides technical rules and practical examples to avoid operational mistakes.
4. Implement CASS 15 Safeguarding Changes (Effective 7 May 2026)
- Plan for mandatory daily reconciliations on reconciliation days (excluding weekends, UK bank holidays, and relevant foreign market closure days)
- Create comprehensive CASS 10A resolution packs with details of safeguarding arrangements, fund locations, agents/distributors, and transfer procedures for potential insolvency
- Upgrade systems to submit monthly safeguarding returns to the FCA within 15 business days of month end
- Focus on today’s safeguarding obligations while monitoring potential trust-based reforms
Status: Final rules published in PS25/12 (August 2025). Firms must comply by 7 May 2026, following a nine-month preparation period.
5. Strengthen Governance and Oversight
- Designate clear senior management responsibility for CASS
- Implement monitoring systems to catch issues before regulators
- Allocate adequate resources to CASS functions
Training: CASS Senior Manager course provides briefings for function holders, while CASS Certification Function course equips certification holders with essential skills.
6. Prepare for Enhanced Reporting and Audits
- Upgrade systems to submit monthly safeguarding returns to the FCA
- Engage auditors early to address emerging CASS assurance expectations
- Plan for annual external safeguarding audits, unless exempt (firms safeguarding £100,000 or less over a continuous 53-week period)
- Ensure safeguarding audit reports are filed with the FCA within four months of the audit period end
Training: All CASS courses at leamancrellin.co.uk help prepare teams for enhanced regulatory scrutiny.
Training Support
Leaman Crellin provides comprehensive CASS training, delivered by experienced compliance professionals and former regulators, including:
- CASS for Beginners – Essential knowledge for new professionals
- CASS Operations – Technical rules for operations teams
- CASS Support Functions – Monitoring compliance and risk management
- CASS Certification Function – Skills for certification holders
- CASS Senior Manager – Briefings for senior management
