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Following a recent Freedom of Information Act request from Rosediem,the FCA have published statistics relating to last year's CASS audit opinions. Within this brief memo,we discuss our concerns regarding these statistics and what they are telling us about the CASS industry.

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With implementation for the extension of the Senior Managers and Certification Regime on 9th December 2019 for solo-regulated firms, it is crucial for firms to begin thinking about how this will affect them; and it is an opportunity for those already under the Regime to ensure all components are being managed effectively. Within this paper, Rosediem have set out some key areas that firms should focus on, both for implementation and to evidence ‘reasonable steps’. The quick guide also provides guidance on prioritising activities.

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The client money calculation rules in CASS, which require a CASS firm to carry out a reconciliation of its internal records and accounts, have been a core requirement of the rule book for many years. However interpretation of the rules varies from one firm to the next and there remains a debate regarding the close of business records for the calculation. Within this paper Rosediem have set out some key concepts and practices regarding the receipting and recording of cash, taking into account both the CASS rules and available operational practices.

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Following a recent Freedom of Information Act request, the FCA have published statistics relating to last year's CASS audit opinions. Within this brief memo, we discuss what we feel these statistics are telling our industry and, more worryingly, what may be going under the radar.

Download the paper here : Free download

The FCA clarified its stance on crypto currency related products in April 2018. For our opinion on this new development please see the attached paper.

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2018 continues to be a busy one for compliance professionals and CASS subject matter experts. Within this paper Rosediem outline some of the main issues firms face adapting to new and changing regulatory developments, such as GDPR, CSDR, SM&CR and Brexit.

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Following the FCA's publication of its policy statement regarding the use of unbreakable deposits to hold client money we discuss what this might mean for firms across the financial services industry. Within the paper the key points of the policy statement are summarized alongside a discussion of the challenges firms may face should they choose to make use of these products.

Download the paper here : Free download

This year has started with a bang for those involved in financial services regulation with MiFID II going live on 3 January 2018. Within this bulletin, we discuss what Rosediem envisages will be some of the CASS hot topics for the year ahead and how these can be best approached by building upon the lessons learnt in 2017.

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Back in July 2017, The FCA released its consultation paper regarding the extension of the Senior Managers and Certification Regime ("SMCR") to all FCA regulated firms. Within the paper the regulator explains how the SMCR will replace the current Approved Persons Regime and what this will mean for the individuals and firms affected. Most of the affected firms will only need to apply the core requirements of SMCR, however, some (to be known as 'enhanced firms') will have extra requirements imposed upon them. The deadline for responses to the CP is 3 November 2017.

As expected, we have already had lots of questions in this space....

In order to help our clients to get ahead of the curve we have drafted this 'Thought Leadership Paper' to help with initial thinking and planning.

Download the paper here : Free download

In Rosdiem's response to PS17/14 we discuss the 'big ticket' items which impact CASS and the main challenges facing our client firms during their MiFID II implementation. As well as summarizing the main rule changes, the paper outlines some of Rosediem's thoughts on the new rules, and how they should be reflected in a firms CASS controls environment.

Download the paper here : Free download

In Rosediem's Brexit paper, 'Brexit – What might this mean for UK financial services?', we explore what the shock referendum result on Friday 24 June 2016 means for the UK financial services industry. In the paper, we discuss some of the possible consequences that our clients as regulated firms or service providers to regulated firms must start to consider.

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"Good Governance: The Key to CASS Compliance" is a white paper co-authored by Rosediem and AutoRek. Within the paper, we explore what good CASS governance looks like and how to achieve it. Whilst we acknowledge that getting governance right in practice is a challenge our approach aims to avoid 'sticking plaster solutions' by creating a framework that is forward looking, rather than incident driven. In the paper, we also explore the ever important topic of managing responsibility and personal accountability risk.

Download the paper here, or from AutoRek's corporate website - quoting "Referral–Rosediem Consulting" : Free download