Client Money and Assets

Since the issues arising from Lehman Brothers International Europe’s Client Money arrangements in 2008 and the more recent MFG collapse, this has been a burning regulatory topic, resulting in a number of enforcement actions being initiated, against firms and their Client Money auditors. These always end up being expensive, either in management time wading through a s.166 review process or in fines levied.

At times, your auditors may not always be the most qualified people to assist your firm as they may have little or no hands on experience of checking your Client Money process. We are able to produce an annual Client Money Report without you having to use your auditor for such a role; this gives you an independent appraisal from people with hands on knowledge.

As part of your outsourcing arrangements and review of your auditors, at the very least you should undertake suitable due diligence to ascertain their abilities in this specialist area. Your analysis should also include whether the audit firm has been reported to the Accountancy and Actuarial Disciplinary Board for failings in Client Money audits.

We have recently written and presented a CPD Seminar for the Chartered Institute for Securities & Investment (CISI) which was opened by the Technical Head of the Client Money team at the FCA. Copies of this presentation are available upon request. The seminar was exceedingly well attended and received. Should you require us to repeat it on an in-house basis, we would make it available at minimal cost.

We provide:-

  • In-house and external CASS training (see training section)
  • The establishment and implementing of CASS polices and procedures
  • Client money/asset health checks, reviews and audits
  • CASS S. 166 review services – skilled persons report preparation
  • CASS S. 166 remediation exercises
  • Advice on any aspect on Client Money, Client Assets or Client Safeguarding
  • Due diligence of Client Money banks and other institutions where client money is held (ie clearers, prime brokers etc)

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