CASS 7 & 7A - Client Money Rules & Client Money Distribution & Transfer

The Client Assets Sourcebook (CASS) outlines a firm's duty to protect customer money and assets. The FCA considers this fundamental to consumers' rights.

Our CASS 7 & 7A: Client Money Rules & Client Money Distribution & Transfer course introduces the rules and guidance around the treatment towards client money. This includes the distribution and transfer of client money.

About this Course

Available as part of our FCA Compliance Library.

Learning Objectives

This course will prepare you to:

Understand the CASS rules for the treatment of client money, including segregation
Keep appropriate records in accordance with the rules of the Financial Conduct Authority (FCA)
Understand why accounting and reconciliations are important
Appreciate the use of third parties, statutory trusts and acknowledgement letters
Know what to do if things go wrong and client money is distributed or transferred to another firm

Course Outline

Welcome

What is client money?

- Why is protecting client money important?
- Client assets or client money?
- The banking exception
- The sections of CASS 7 & 7A
- You decide: The CASS rules

Treatment of client money

- Key terms
- DvP transaction exemption
- Money due & payable to our firm
- Discharge of fiduciary duty
- Transfer of business
- Allocated but unclaimed money
- You decide: Unclaimed money
- You decide: No response

Organisational arrangements

- Third-party records
- You decide: Payment by cheque

Segregation of client money

- The normal approach
- A 95-day unbreakable deposit
- Designated bank accounts
- Diversification of client money
- Mixed remittances
- Physical receipts of client money
- Prudent segregation
- The alternative approach
- Adopting the alternative approach
- You decide: Segregating client money

Using third parties

- Client transaction accounts
- You decide: Which account?

Keeping records

- Reconciliation records
- Systems & controls
- Internal client money reconciliations
- Identifying a discrepancy
- External client money reconciliations
- Notifying the FCA
- You decide: The internal reconciliation

Statutory trusts

- Trustee firm record-keeping
- You decide: Who is responsible?

Acknowledgement letters

- FCA-prescribed templates
- Retaining the letters
- You decide: New wording

CASS 7A & trustee firms

- Primary pooling events
- Secondary pooling events
- Secondary pooling shortfalls
- Mixed remittance
- You decide: The secondary pooling event

Summary

Affirmation

Assessment

Course Specifications

Structure

Approximately 50 minutes followed by a 10-question assessment.

Audience

Suitable for all staff - examples and interactivities designed for staff at all levels. No previous knowledge or experience is required.

Design

SHARD-compliant, responsive display on all devices, accessibility on screen readers, visual design controlled via client style sheet.

Compatibility

All Windows, Mac OSX, iOS, Android (Flash-free for mobile compatibility). AICC and SCORM 1.2-compliant, suitable for both hosted and deployed SCORM or AICC.