Advised a global banking institution on the CASS arrangements in place in its UK investment business

The Bank currenly has a small investment business but is looking to grow its footprint. We were asked to review the current CASS arrangements to assess whether they were currently compliant with FCA requirements and market practices and to advise on improvements that may be needed as the Firm grows its business activities.

We performed a full review of the Firm’s CASS 6 and CASS 7 reconciliation arrangements, contracts with counterparties, sub-custodians and other banking institutions and performed an end to end walkthrough of the Firm’s systems that are used for CASS processes.

We futher reviewed the Firm’s policies and procedures and mapped its current arrangements to current CASS requirements, assessing whether there were any current gaps in compliance. Having completed this part of the work, we assessed the Firm’s CASS controls against the expected trajectory of the business, to identify any potential sustainability issues in the Firm’s current arrangements.

We advised the Firm on some enhancements that would be needed to Client Asset reconciliation arrangements as the footprint grew. We also recommended some additional clarity in specific technical areas of CASS that we felt would help the Firm both ensure continued compliance and demonstrate more clearly its arrangements to third parties