December 1st was an important deadline for CASS regulated firms as the second wave of changes under the CASS policy statement 14/9 came into effect covering areas including increased transparency to clients around their assets.
- Modifications to agreement templates for all new client and third party contracts should now be in place
- Transparency through ensuring that all new clients are made aware of how their custody assets and cash are being held is now mandatory for firms
If not already, firms now need to turn their attention to the third and final wave of rule changes under the policy. These become effective next year on 1st June 2015.
Areas to consider and address are:
- Re-papering of existing client and service provider agreements
- General process and recording keeping impact of CASS policy updates
- Specific changes to the way firms receive client money under the ‘normal’ approach to meet the immediate segregation rules
- Recording of non-written mandates and managing effective controls to ensure compliance
- Working with auditors to ensure continued compliance demonstration of both the ‘alternative’ and ‘normal’ segregation approaches