Client money and asset protection (CASS) records can range from the transactional to the evidencing of thought processes. There are multiple levels and types of records to be maintained, with different audiences to inform. Firms need to be mindful of the requirements of each audience, which may vary according to the expertise of that audience, the reasons why the record is needed, and the reliance placed on those records.
CASS related documentation therefore needs to consider appropriate levels of detail and the potential readers of the evidence provided. Broken down into four key sections, this whitepaper explores and challenges different points of consideration for maintaining adequate records to meet the Financial Conduct Authority (FCA) recordkeeping requirements.
Recordkeeping for CASS may seem to cover a plethora of different types of record. Some records are fundamental to achieving and proving the accurate and complete basic records of transactions and positions. Others support management, the Board, auditors, and others to assess and manage CASS compliance.
In this paper, we have set out four key areas where CASS recordkeeping evidence is required and explore some of the factors which apply to each. These areas are:
- Transactions and Positions
- Procedures and Actions
- Policies and Decisions