I’ve been producing numerous CASS rule mappings for clients for FRC CASS Assurance Standard purposes over many months. Its a laborious exercise but it does yield real benefits for firms if it is done in sufficient detail. There really are no short cuts but, as I do more mappings, I’m finding ways to make the process much more effective and efficient.
Like so many CASS related projects a CASS rule mapping should not be viewed as a ‘one-off’ project. It should not just be another appendix for your CM/CASS manual that sits on a shelf unread/gathering dust until the next CM audit. In my experience the bigger risks to CM protection and CASS compliance come when there are changes in the business. Clients often do a project to tighten up their CASS process then, over time, someone changes something that wasn’t anticipated or built into the design of processes/controls or the CM calculation. Your CASS rule mapping needs to become a living document that is referred to and adapted on every business change before it happens. However the CASS Rule mapping is necessarily detailed and, in all its glory, will make those less familiar with CASS confused/bored or probably both!
If your doing your own CASS mapping, one tip I can strongly recommend is that you generate a simple a set of ‘CASS Operating Assumptions/Statements’ as you work through your mapping. This may sound a bit grand but all they need to be are very simple statements that everyone in the business can understand. For example: “XYZ Brokers Ltd does not permit Appointed Representatives to handle Client Money”, “XYZ Brokers Ltd does not agree to account any interest to Clients or Insurers”, “XYZ Brokers Ltd do not use Designated Client Bank Accounts”… and so on. These should encapsulate the assumptions/assertions that you make as you complete your CASS rule mapping and determine which sections of the CASS rules are not-applicable to your business.
When you have completed your CASS mapping you can share these CASS Operating Assumptions/Statements with everyone in the business. This will allow everyone to fully understand in clear and simple terms, (as non-CASS-experts),the parameters within which they must operate with regards to handling Client Money. Where they want to make a change and do something that runs against one of the CASS Operating Assumptions then they must consult the firm’s CMM before doing it.
All too often the knowledge of CASS requirements rests with a few central ‘CASS Luminati’ ( The CMM and a few Accounts,IBA or Compliance people). It is often difficult for these people to know every change/development that is occurring before it happens. Having a published clear and simple set of CASS Operating Assumptions is the best way to equip the rest of the people in the business with the knowledge they need to play their part in protecting Client Money and maintaining CASS compliance. With a well crafted set of CASS Operating Assumptions in place, CM Protection and CASS compliance can definitely become a much more effective ‘team effort’ for your firm!
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