A tier one global Investment Bank required a business and functional analysis of their post-Brexit client money management solution. The bank’s London Branch required a regulatory reporting solution to satisfy FCA Client Asset Sourcebook (CASS) and Client Money Asset Return (CMAR) obligations.
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This was required in order to gain UK authorisation and compliance with the FCA’s CASS rules to facilitate the safeguarding of client assets which have previously been met via EU passporting to the home regulator.
How Citihub Consulting Helped
Citihub Consulting provided advisory services and subject matter expertise to lead a discovery exercise. The purpose of this was to understand the regulations in question (CASS 6 & 7); to scope and define the following items:
- Golden source data definition for client asset position and client money valuation data, reconciliation and break data, and agent bank and custodian registration practise static data;
- Key CASS operation and IT process identification across impacted front office businesses;
- Control owner engagement, framework design and execution with control gaps recorded for future remediation;
- Support for Temporary Permissions Regime (TPR) to allow the bank to continue to operate for a limited period while they seek authorisation if passporting falls away in the event of the UK leaving the EU under a no deal scenario. This included the Temporary Permissions Client Asset Return (TPCAR);
- Business and Functional Requirements;
- Design architecture for central RegTech reporting solution aligned to the bank’s data distribution strategy;
- Completeness and Controls for IT reporting solution.
Citihub Consulting became a trusted partner to business, technology & operations teams and aligned delivery across the RegTech team, the CASS Office and the central CASS project team.