CASS Compliance and Transfer Agent Oversight


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.

The Challenge

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:

  • Manually mapping the applicable rules to the appropriate controls, risks and related business processes
  • Documenting attestations to confirm compliance
  • Creating and maintaining an up-to-date resolution pack (maintained in SharePoint)
  • Recording risk events and breaches (also managed in spreadsheets), and
  • Ensuring that all these disparate elements of their CASS framework were kept up to date on an ongoing basis

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