Client Assets, Prudential and CFO Services
Client assets and prudential regulation are among the areas where FCA-regulated firms carry the most direct and personal regulatory exposure. The client money and asset rules are tested through an annual, binary audit, and CASS oversight sits with a named individual under the firm's senior management arrangements. Prudential risk is assessed annually through the ICARA process, and tested under supervisory challenge.
Objectivus provides client assets expertise, prudential support and senior finance leadership to FCA-regulated firms, at the level and frequency actually needed — from ongoing ownership of the CASS and prudential framework, through remediation following an unsatisfactory audit or regulatory undertaking, to fractional or interim CFO cover where a permanent, full-time hire is not the right fit.
Our client assets and prudential services include:
- CASS classification and scope reviews, client money and asset reconciliations, the CASS Resolution Pack, CMAR, breach registers and CASS 6, 7 and 8 control frameworks
- Support for firms holding CASS operational oversight responsibility, and for cryptoasset custodians preparing for the CASS 17 safeguarding requirements
- Remediation of qualified or unsatisfactory CASS audit opinions, financial audit findings, section 166 reports and voluntary requirements, from findings through to evidenced closure
- Own funds and liquid asset threshold requirement calculations, K-factor mapping and methodology review, and the ICARA document and the process behind it
- Stress and reverse stress test modelling, and wind-down planning that is costed and triggered rather than described
- Prudential requirements under the incoming COREPRU and CRYPTOPRU sourcebooks for cryptoasset firms, including sourcebook scoping and prudential input to authorisation applications
- Fractional and interim CFO cover, including board and regulatory reporting, cash and liquidity management, and ownership of the audit relationship
Recent assignments have included:
- Remediating a CASS control framework following an unsatisfactory annual audit report
- Building a client money and asset safeguarding framework for a new fixed income or digital asset product
- A full ICARA rewrite, including stress and reverse stress test scenarios and own funds calculations
- Independent review of regulatory filings and K-factor methodology
- Interim CFO cover during a management transition, an in-housing of outsourced finance, or a general ledger implementation
- Exiting a voluntary requirement or other regulatory undertaking
- Prudential and client assets input to an authorisation or licence application
Contact us to learn more about our Client Assets, Prudential and CFO Services.
