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Case Study

BREXIT: CASS Client Money Asset Return (CMAR)

Rule analysis, requirements definitions and strategic design approach for BREXIT Preparation

Customer Challenge

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.


Client Benefits

Regulation Technology Experience

The detailed analysis across a full set of custody, operations and technology stakeholders enabled a transparent debate on the focus areas for regulatory compliance and operational efficiency.

A golden source data definition was produced alongside the requirements definitions. This provided clear guidance on technology and operations process implementation designs and impact prioritisation.

Key to this was Citihub Consulting’s expertise at leveraging previous Brexit and regulatory project experience (e.g. MiFID) plus wider industry knowledge for technology programmes of work.

Consensus Building

Once the requirements and architecture design were proposed, there was an extensive exercise to build consensus. This was achieved through working groups attended by technology, operations, CASS Office and project teams.

Concerns and issues were addressed as the proposed design evolved. Close engagement of stakeholders resulted in an agreement across stakeholders including design authorities. Citihub Consulting takes an egoless approach to consulting engagements ensuring that the client achieves the best outcome.

Driving Execution

Citihub Consulting delivered signed-off requirements and design architecture documentation that led to an implementable regulatory reporting solution.

Technology development build and operational processes were tracked through weekly working groups to ensure compliance in accordance  to agreed timescales.