What has changed?
Firms such as financial advisors, investment managers, stockbrokers, debt management and claims management firms usually need an annual client asset (‘CASS’) audit in addition to any statutory audit – and their CASS auditor submits the report directly to the FCA within four months of the period end. This contrasts with CASS audits for insurance brokers, in which the report is delivered to the broker rather than submitted to the FCA, although the deadline is the same. The FCA currently receives around 3,500 CASS audit reports per year.
Until now, the usual method of submitting CASS reports to the FCA has been via email. Earlier in 2019, the FCA indicated that they intended to move such submissions onto their Connect online reporting system (which is already used by FCA firms for some of their submissions, alongside the GABRIEL system).
How do we register with Connect?
The FCA has recently issued guidance for auditors detailing how the new regime works, and how to register with Connect. The 23-page guidance walks users through the process, with screenshots of the application stages in Connect. A copy of the guidance can be found here https://www.fca.org.uk/publication/systems-information/how-to-submit-client-asset-reports.pdf
How soon should we register?
Although the FCA has not indicated a deadline for registering on Connect, the system appears to be operational and CASS auditors should begin to use it immediately.
Is there a wider impact on our CASS audit work?
No. The CASS rules, deadlines and audit process is unchanged.
However, we noted in our recent blog article that a new CASS Assurance Standard was published in late November. We will issue updates to the relevant Mercia Specialist Assignment Manuals (FCA-DIF and FCA-MGI) in early 2020 to reflect the new Standard and new guidance on submission of CASS reports will be added.