CASS - the current state of play

  • March 15, 2019

We interviewed Elaine Sutton, an experienced CASS professional and CF10a at Sova Capital Limited, to find out more about the current state of the CASS sector.


From your experience, what have been the biggest challenges, both as an individual and as a firm, working in the CASS space? How have you dealt with these?

When first coming into the CASS space I hit the ground running so to speak as there was such little industry knowledge and documentation available on the subject.  Firms were getting fined by the FSA later the FCA for CASS breaches for millions of pounds.  In addition, after the Lehman’s and Man Global collapse, clients both professional and retail didn’t trust placing their funds into UK based companies. There was a lot of pressure on CF10a’s to make sure that their firms CASS compliance and governance was in line with the rules and FCA expectations or woe betide.  Mercifully those days have now passed although still I hear some scary stories of firms not getting their CASS compliance and governance right from time to time.

Interpreting the CASS handbook and how the rules fit into the firms business is what I believe is one of the biggest challenges. The CASS handbook is a ‘one size fits all’ which can be tricky when new rules are applied. I generally implement what I believe is the best solution to ensure CASS compliance then try to find out what the business norm is. Thankfully I haven’t made any errors of judgement.

What role does technology have to play in maintaining CASS compliance?

CASS compliance is heavily dependent on technology across the board, especially given the level of detail that’s required.  However, it also can hide a magnitude of sins if not monitored closely. My top tip is, if you are looking at full automation, perform ‘checks and balances’ to ensure that all your underlining data ties back.

What significance does training and continuous learning and development have to play in maintaining CASS compliance?

CASS is not a one person nor team effort but the involvement of a whole firm. From the on-boarding of a client until the discharge of fiduciary duty. CASS training is fundamental for all authorised firms to maintain compliance with the rules.

What affect do you think SM&CR will have on the role of the CF10a?

There are two schools of thought here given that the FCA has advised that CF10a role should be considered under the certification regime. The first is that it may reduce the importance of the CF10a’ s role by reporting into a Senior Manager and diluting the accountability element, the second is that it may provide the CF10a with more gravitas.  A senior manager allocated with the overall responsibility of CASS is more likely to want to be involved with CASS compliance and the CF10a if they are also accountable. Although I’ve noticed that some firms are moving their CF10a’s into the SMF18 – Overall Responsibility Function.

What does the future hold for CASS compliance and the role of a CF10a?

I would like to say that the CF10a role will become easier over time but with our ever changing regulatory landscape I don’t really see that happening. New products and business lines are always in development, keeping the CF10a forever on their toes, for example, the firm I’m currently working at is the first UK broker to have CASS segregation up at the Moscow National Clearing Centre.

What advice would you give to someone looking to pursue the CF10a pathway?

Gain as much operations experience in the financial services industry as you can. Understand all the different financial products and settlement flow.  My background is in both operations and finance which is so valuable when making informed decisions.

Thanks Elaine!

Elaine is a senior manager who has worked in the financial industry for over 25 years. Elaine has both a finance and operations background, and has been working in the CASS space for seven years - two years at a third party outsource provider and the past five years at Sova Capital Limited, a Russian Brokerage House. Elaine has been CF10a for three years now.

Find Elaine on LinkedIn.




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