Handling Client Money in Claims Management - Meeting CASS 13 Requirements

Course Outline & Objectives

The claims management sector is relatively new to FCA regulation. The FCA views client money handling as a key risk, no matter what sector: central to consumer protection and managing conduct risk, even if the amounts held are relatively small. 

The Client Assets rules (CASS 13) are complex and can be a source of misunderstanding.The rule based regime means it all too easy to unwittingly create technical breaches. Rigorous supervision continues to reveal breaches and enforcement action continues against both small and large firms, and executives within them. 

This is a forum to analyse and explore CASS 13, in the wider context of FCA supervision, and discuss the practical application of a rule based “zero tolerance” regime.

Attending this course will help you:

• Appreciate the FCA’s expectations of this rule based, zero tolerance regime
• Navigate the Client Money Sourcebook, Ch 13: “CASS 13”
• Avoid technical breaches and failures which potentially have customer detriment
• Apply practical solutions to the management and oversight of your client money procedures and controls
• Position the governance of CASS within the Senior Manager and Certification Regime

Who will benefit?

Anyone with oversight or operational responsibilities for handling client money in a claims management company.

Course Agenda

Topics covered may include but are not limited to:

• High level responsibilities of firms, and their senior managers, when handling client money
• Key requirements of the CASS sourcebook
• What should be covered within formal procedures, competence and “the client money file”
• CASS and the Senior Manager and Certification Regime
• Which breaches are notifiable to the FCA: the “must” v the “should”
• FCA concerns and practical solutions
• Operational implications within your own firm and identify changes that may be required
• Lessons from FCA enforcement actions