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CLIENT MONEY
REGULATORY FINES
The Client Assets Protection Regime
The regulator’s overhaul of the Client Assets Protection Regime (CASS) in 2014 will affect how firms handle client money and assets going forward, through their:
customer relationships
outsourcing arrangements
IT systems
Operations; and
the policies and procedures that they have in place.
The third and final stage of implementation of the new client money rules was adopted on 1st June 2015.
The first stage of the new CASS rules took effect on 1st July 2014 and the second stage, implemented on 1st December 2014, saw rules that required the re-papering of client documentation.
From June 2015, businesses now need to have implemented all new CASS rule requirements including those that that require big changes to IT systems.
Compound Growth can assist firms of all sizes to ensure they have the necessary procedures in place to remain compliant with the regulator’s rules pertaining to client money and client assets as set out in the CASS Sourcebook.
In particular we can support your firm in establishing suitable accounting systems as well as developing client money policies in line with industry best practice and the FCA’s guidance.
Overview of the implementation timeline for the new Client Money and Client Assets rules.
1st June 2015
Firms will need to ensure they fully comply with all of the new rules set out in Appendix 1 to the FCA Policy Statement 14/9.
1st December 2014
Certain rules came into force relating to the provision of information to or relating to the agreements and documenting of these with any new counterparty with whom firms deposit or otherwise place custody assets or client money.
1st July 2014
Certain rules and guidance came into effect providing clarifications to existing requirements, introducing optional arrangements with which firms may choose to comply and limiting the placement of client money in new unbreakable term deposits.