Senior Managers with prescribed responsibility for CASS are directly accountable for it and must take reasonable steps to protect client money and comply with CASS.  A  comprehensive CASS rule mapping  and robust control over the wordings of insurer TOBAs and binders are the two fundamental first steps.

If your external CASS audit report is 100% clean, this probably indicates a poor audit not perfection on CASS control.  A certain level of error and CASS breach is to be expected. Managers who over-rely on external CASS audits that fall  short will be left very exposed.  Testing and monitoring client money and CASS controls is a responsibility of the Senior Manager that cannot be outsourced to the external CASS auditor.

A proactive solution

Initiating a specific CASS Health-check that is independent of the external CASS audit demonstrates that you are taking a proactive approach to detecting and addressing your CASS issues.  If you are looking for experienced support on reviewing your CASS controls through a comprehensive CASS Health-check then simply get in touch using the form on the right.  BRP has devised a checklist to assist CEOs and Senior Managers in addressing the many detailed issues raised in the FCA’s Dear CEO Letter – Adequate Client Money Arrangements – For General Insurance Intermediaries issued on 30 September  2020.