We have issued three letters addressed to CEOs of firms which hold client money and/or custody assets as part of their business to remind them of their obligations under the Client Assets Sourcebook (CASS). Information on this page was last updated in 2021.
On this page
Dear CEO letters
These Dear CEO letters highlight the areas that are important to maintaining adequate client assets arrangements in the current environment.
- Dear CEO letter: Adequate client assets arrangements (for firms holding client assets relating to investment business, debt management or claims management).
- Dear CEO letter: Adequate client assets arrangements GII (for firms holding client money relating to insurance distribution).
- Dear CEO letter: Maintaining adequate client money arrangements GIIs (for firms holding client money relating to insurance distribution).
These letters are relevant for all firms which hold client money and/or custody assets. Firms should consider carefully which sections apply to their arrangements.
Our client assets regime is designed to protect consumers’ money and custody assets. Market participants and consumers should have confidence that their client assets will be protected, including in the event of insolvency.
The continued impact of the coronavirus (Covid-19), combined with other key events, such as the end of the EU withdrawal transition period, mean that the entities we regulate are being affected in ways that would have been difficult, if not impossible, to predict previously.
Firms should review their client assets arrangements in the specific areas set out in the letters, considering the current economic environment. Where deficiencies are identified, firms should take immediate action to rectify them. We also expect firms to notify us of any material concerns identified while reviewing the adequacy of their client assets arrangements.
These letters are in addition to the letters we have recently issued on:
- Dear CEO letter: Inappropriate use of Title Transfer Collateral Agreements
- Dear CEO letter: Increased client money balances
- Dear CEO letter: Senior Partner/Director of the audit firm – Reporting obligations
Where a regulated firm has a query about how to apply the CASS rules in the current circumstances, it can contact us by emailing [email protected].
As usual, we expect firms to have taken reasonable steps to research and analyse the topic before approaching us (and in some cases, where possible, it may be helpful for firms to obtain professional advice). We will treat any such requests for guidance in line with our approach set out in SUP 9.2.