CASS large firms are beginning to add a further layer to ensure CASS Compliance by introducing a CASS SME role within the 2nd line. This reduces the risk of any breaches going unnoticed by having a CASS Expert sitting within the Compliance team.
Following multiple fines due to failures in the oversight of firms TPA and other external partners, firms have looked to shore up the relationship management skills within the CASS team. This improves the accuracy of the firms' TPA and gives the firm an opportunity to push back when necessary.
Following the new FRC Assurance standards in 2017, firms have increased resources from a 3rd line/Assurance perspective. Last year, the regulator had likely been more lenient as it was the first year of the new audit standards, though the same can’t be said for 2018. Increasing expertise in the assurance space reduces the risk of an adverse audit.
With the pending impacts of the Senior Managers & Certification Regime, smaller firms with multi control function holders in post will likely have to bring in someone to solely concentrate on each regulation. For example, each firm will either have to document the percentage of time dedicated to CASS, Compliance and AML, or they will have to appoint an individual for each regulation (e.g. a separate person for CF10, CF10a & CF11).