Knowledge Base
Welcome to the CMAC Knowledge Base – your trusted source for practical guidance on the FCA’s Client Asset Sourcebook (CASS).
Whether you're new to CASS or a seasoned compliance professional, this space is designed to help you save time, reduce risk, and strengthen your internal controls. You'll find structured resources, plain-English explanations, and downloadable tools to support your day-to-day work across client money, custody assets, and the wider CASS regime.
What is CASS?
The FCA’s Client Asset Sourcebook (CASS) sets out rules to protect client money and assets held by regulated firms. It ensures firms safeguard client property in the event of failure, minimise misuse, and maintain market confidence. CASS applies to a range of investment firms, platforms, and custodians, depending on their business model. This section introduces the regime’s purpose, scope, and structure, and helps firms understand their obligations under the various CASS chapters. Whether you're new to CASS or need a quick refresher, this guide provides the foundational knowledge you need to comply with the rules.
Client Money
Client money refers to money a firm holds or receives on behalf of clients in the course of investment business. The CASS 7 rules ensure this money is kept separate from firm money, properly reconciled, and protected in the event of firm failure. This section covers the key requirements including segregation, bank accounts, acknowledgements, daily client money calculations, and record-keeping. We also explore common risks, practical control examples, and how to maintain robust oversight in line with FCA expectations. It’s a must-read for anyone handling or overseeing client money operations.
Custody Assets
Custody assets are securities or other investments held by a firm for a client. The CASS 6 rules ensure these assets are safeguarded through proper registration, record-keeping, and reconciliations. This section explains how to maintain adequate protection, the use of third-party custodians, and how to avoid shortfalls. It also highlights key operational risks and common breaches. Whether you’re responsible for custody reconciliations or oversight, our guidance helps ensure strong asset protection and compliance with the FCA’s expectations.
Mandate Rules
Mandates are permissions a firm holds to give instructions on a client’s behalf, such as instructing a bank or broker without holding the assets. The CASS 8 rules apply when firms retain such permissions without taking custody or client money. This section clarifies when the mandate rules apply, how to document and control them, and what the FCA expects in terms of oversight and reporting. A practical area that’s often misunderstood, understanding mandates can help prevent inadvertent breaches and strengthen your firm's client asset controls.
CASS Resolution Pack
The CASS Resolution Pack is a critical tool designed to help administrators locate and return client assets promptly in the event of firm failure. Required under CASS 10, it must contain up-to-date records and key documents that demonstrate how client assets are held, controlled, and protected. This section explains what must be included, who’s responsible, and how to keep the pack current. With growing FCA focus on wind-down planning and operational resilience, maintaining a strong CASS RP is more important than ever.
CASS Audits
Firms subject to the CASS rules typically require an annual CASS audit by an FCA-registered auditor. The audit assesses whether the firm has maintained systems and controls that meet the CASS requirements. This section outlines the scope, process, and reporting expectations of CASS audits, including the difference between reasonable assurance and limited assurance reports. We provide tips on preparing for audit, avoiding common findings, and using the audit process as a catalyst for strengthening internal governance.
CMAR
The Client Money and Asset Return (CMAR) is a regulatory return submitted via RegData by medium and large CASS firms. It provides the FCA with a snapshot of the client money and custody assets held, and the firm’s control environment. This section breaks down what the CMAR includes, who needs to submit it, and common pitfalls in its preparation. Accurate CMAR reporting is critical for regulatory oversight and helps firms demonstrate effective control over client assets.
Jargon Buster
The world of client asset regulation is full of technical terms and acronyms. Our Jargon Buster provides plain-English definitions of the most common CASS terms – from “Acknowledgement Letters” to “TTCA”. Whether you’re new to the rules or just need a refresher, this section helps decode the language of compliance, making your day-to-day role easier and more confident. It’s a handy reference for training, internal documentation, or just when you’re stuck on an unfamiliar term.