Breach Management, Checklists and Control Testing
The Challenge Using spreadsheets and other disparate resources to record incidents and breaches and to manage the firm’s risk control matrix
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CASE STUDY
A UK-based investment management company with more than £50 Billion assets under management (AUM). The firm is a FTSE 250 company listed on the London Stock Exchange.
A manual approach to CASS compliance
The client is a large CASS firm and is therefore required to comply with applicable FCA client money rules. The company currently outsources elements of its CASS operations to a transfer agent and as per the relevant CASS outsource rules was required to put in place the necessary processes and controls to oversee that critical outsource relationship.
To facilitate compliance with the CASS rules and the FRC standards, the firm relied on an Excel spreadsheet to manage its CASS control matrix. Rules were sourced manually from the FCA website and copied and pasted into the spreadsheet. The CASS team was then faced with a set of challenging tasks including:
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