FCA has written 2 Dear CEO letters to firms that hold client money or custody assets, whether in the context of investment or insurance business, to remind them of their obligations under CASS. The letters stress that the continued impact of Covid-19, coupled with Brexit and other events, have led to completely unforeseen effects on firms. FCA is calling on firms to review their arrangements in the specific areas the letters address, and take immediate action both to put right any failings and to tell FCA about any material concerns they identify. The letters cover a range of concerns, under the headings of:
- governance and oversight
- oversight of third parties
- adequate records and reconciliations
- acknowledgement letters for all client money accounts (where relevant)
- CASS Resolution Packs (where relevant)
FCA has previously given guidance on specific queries it received on the difficulties of complying with certain requirements during the pandemic.