| 32. | It is critical for the firm to understand the interrelationship of its business model and inflows and outflows of cash and assets with the CASS rules. It is important for the CASS auditor to be knowledgeable of the firm's understanding of the interrelationship. Following the crisis, investment firms (but not insurance intermediaries) are now required to appoint an individual to be responsible for oversight of the firm's operational compliance with CASS. Dependent on the quantum of client money or assets held, this individual is either appointed to fulfil a controlled function known as the CF10a or is a director or senior manager approved for another significant influence function. |
| 33. | The Client Money and Asset Return (CMAR), which a firm is required to submit to the FCA periodically, is intended to give the FCA an overview of firm-specific CASS positions and an overview of CASS holdings. |
| 34. | The CASS auditor is not required to report on the firm's compliance with the CMAR requirements. However, reading the CMAR is likely to assist the CASS auditor in understanding the firm's business. The CASS auditor, therefore, should review the firm's CMAR submissions and assess their consistency with its knowledge of the firm's business. If such reviews reveal inconsistencies between the CMARs and the CASS auditor's understanding, it seeks to understand the reasons for the inconsistencies. |
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