CASS: Client Assets Policy


Do You Need a Client Assets Policy?

Are you holding or controlling clients assets or money?

Are you a peer to peer lender?

Accoring to the FCA Handbook, the Client Assets Sourcebook (CASS), whenever you hold or control client money or safe custody assets as part of your business, you need to have a policy in place to describe the decisions, procedures and other relevant information.

This is to keep client money and assets safe if firms fail and exit the market.

To reduce the risk of financial loss, you should:

  • identify risks
  • assess risks
  • mitigate (reduce) risks

Firms holding or controlling client assets must report the value of their assets. This includes:

  • brokers
  • investment banks
  • custodians

CASS classification
Your CASS firm type (small, medium or large) is based on the size of your client money and/or custody asset holdings.

Your firm must make an annual notification about the money and assets you hold to identify if you are small, medium or large. This will enable you to see what your firm’s classification will be (see CASS 1A.2).


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