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Mandates

Client Mandates: Control, Clarity, and Compliance

Client mandates are a critical — and often underestimated — aspect of the FCA’s CASS regime. They determine how and when firms can act on behalf of clients without receiving or holding client money or assets directly.

Poor mandate oversight can create “shadow CASS” risks, where a firm unknowingly performs regulated activities without proper controls or disclosures. At CMAC, we help you stay on top of your obligations, mitigate risk, and clarify your responsibilities when it comes to written and non-written mandates.

📘 What Are Client Mandates?

A mandate is the authority a client gives to a firm to control their money or assets, typically without the firm taking possession.

Under CASS 8, firms must:

  • Identify mandates (written or non-written)

  • Maintain appropriate records

  • Implement governance and oversight controls

This is particularly relevant in:

  • Discretionary investment management

  • Standing instructions (e.g. direct debit setups, third-party transfers)

  • Adviser charging and automated rebalancing

🔍 FCA CASS 8 Definition – View Handbook →

✅ When CASS 8 Applies

A mandate is in-scope under CASS 8 if:

  • The firm can initiate transactions or instructions relating to client money or assets

  • The mandate does not require further consent from the client at each use

  • The client money or assets are held outside of the firm’s control (e.g. directly by a custodian or bank)

🧠 Out of scope examples: simple advisory relationships, one-off instructions, or where the firm only transmits client orders without discretion.

⚙️ Best Practice for Managing Mandates

1. Identification & Classification

  • Maintain a Mandate Register that clearly records:

    • Type of mandate (written / non-written)

    • Scope of authority

    • Controls in place

📄 [Download Mandate Register Template →] (Download link)

2. Internal Governance

  • Ensure appropriate segregation of duties

  • Regularly review mandate use in operations and control teams

  • Include mandate oversight in CASS Committee reporting

🗂️ [Mandate Monitoring Checklist →] (Download link)

3. Control Over Access

  • Restrict and log who has access to mandate authority (e.g. payment systems, portals)

  • Document changes in personnel and system permissions

🔐 [View Access Control Best Practice Guide →] (Internal page)

🚨 Common Issues and Risks

  • Failure to register a mandate that grants indirect control

  • Non-written mandates overlooked (e.g. firm-initiated transfers or rebalancing instructions)

  • Gaps in oversight where Ops, IT, or third-party platforms enable actions without CASS checks

  • Inadequate breach reporting or RCA when mandate controls fail

📋 [Mandate Breach Log & Root Cause Template →] (Download link)

❓ Mandates FAQ – Real Questions from the CMAC Community

Q: Is a discretionary investment agreement a mandate?
Q: What about client authority to withdraw fees directly?
Q: How should mandates be controlled across outsourced platforms?

💬 [See Full FAQ →] (Internal FAQ page)
📣 [Ask the Forum or Share Your Practice →] (Community forum link)

🧷 Key Regulatory Links & Resources

📚 [Browse All Templates & Tools →] (Internal resource hub)

🌐 Join the Conversation

How are firms identifying and governing non-written mandates in 2025?
Join the CMAC community to share insights, download tools, and stay ahead of regulatory expectations.

🔐 [Join CMAC (Free Membership) →]
💌 [Subscribe for Mandate Compliance Alerts →]