Handling Client Money in General Insurance - 16/10/2018
The Training Environment For Financial Services

Handling Client Money in General Insurance

16 Oct 2018, Birmingham

9:30am to 4:30pm

Outline & Objectives

The FCA views client money handling by general insurance intermediaries as a key risk, central to consumer protection and managing wholesale conduct risk. But the Client Assets rules (CASS 5) are complex and continue to be a source of misunderstanding, especially for smaller brokers. Rigorous supervision continues to reveal breaches and enforcement action has ramped up against both small and large firms, and executives within them.

This one-day workshop is a forum to analyse and explore CASS 5, and discuss the practical application of a rule based “zero tolerance” regime with other client money professionals. The significant enforcement actions are also discussed.

Attending will enable you to:

  • Explain the responsibilities of firms, and their senior managers, when handling client money
  • Outline the FCA's High Level Standards that impact on handling client money
  • Define the key requirements of the CASS sourcebook
  • Examine how the rules apply in practice, drawing on industry good practice
  • Determine what should be covered within formal procedures, competence and "the client money file"
  • Identify which breaches are notifiable to the FCA: the “must” v the “should”
  • Highlight specific FCA concerns and practical solutions
  • Assess the operational implications within your own firm and identify changes that may be required
  • Learn the lessons from FCA enforcement actions

Who will benefit?

This event will be of value to Directors and Senior Managers with client money responsibilities, (direct or oversight) Accounting staff and supervisors, Compliance officers and Internal Auditors.

Training Approach

This in an interactive course with full support notes combining visuals and “plain English” narrative explanations as a post course reference.

Course Leader

John Constable has over 20 years' training experience with both insurers and brokers. He was Head of People Development at JLT where he engineered a number of critical projects to support the business, including the development and implementation of robust structures, policies and procedures to comply with regulatory requirements for Training & Competence. He now runs regulatory, risk management and financial training, bringing commercial awareness, credibility and pure energy, to open courses, bespoke in-company works and board briefings. In addition, John authors industry on-line learning and his published articles have included several on Solvency II. John has a BA (Hons.) History degree from Kings College London, holds a financial qualification from the Open University, a Diploma in Management from Henley Management College and is a Member of Chartered Institute of Personnel and Development.

Course Agenda

The High-Level Standards: PRIN and SYSC implications for client money

  • The CASS sourcebook rules in detail
  • What constitutes client money?
  • Risk transfer, co-mingling and subordination
  • Terms of business agreements, and the risks associated with Risk Transfer
  • How the CASS rules apply fiduciary responsibility across the broking chain
  • Segregation: comparing statutory and non-statutory trust accounts and their operation
  • The client money calculation and reconciliation
  • The external client money audit

Practical “mapping” of the client money process

Conduct risk: applying best practice to your own procedures

Senior management responsibilities for governance and oversight

Exploring enforcement actions: clarifying application - what can we learn?

This course can be delivered in-house at a time and location to suit your business and tailored to suit your people and organisation. We can also create bespoke training when something very specific is needed.Please contact us to discuss your requirements in more detail and at no obligation.

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