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The FCA issued Consultation Paper CP24/20 in September 2024 to consult on changes to the Client Assets Sourcebook. The proposed changes will bring payments and e-money firms into the scope of CASS rules for the first time, bringing significant change to many of those firms.
The proposed rules are more prescriptive than previous guidance. Whilst the detail may be welcomed by firms, it will bring the need for significant effort to prepare for the new requirements. We can expect a short implementation timeframe of 6 months for the first phase of the implementation, so firms should act now to understand what they need to do to prepare themselves.
In this webinar, we will look at the proposed rules and discuss what they will mean in practice for firms and the challenges they could bring. We will give attendees a good understanding of the possible impact of the changes on their firms. We will also discuss what firms should be doing to prepare for the changes and will offer suggestions for immediate steps that can be taken. We will equip attendees with the knowledge to be able to formulate a plan and make sure they can act quickly to be ready for the implementation of the interim state rules.
Director, Issuing & Acceptance, UK Finance
Principal Consultant, Square 4
Chloe is a Principal Consultant at Square 4 with over 16 years financial services experience, having worked in retail banking, at the regulator, as a ...
Chloe is a Principal Consultant at Square 4 with over 16 years financial services experience, having worked in retail banking, at the regulator, as a consultant at a ‘big 4’ firm, as well as within multiple firms in the asset and wealth management sector.
Chloe has been specialising in CASS for over 8 years, leading CASS functions at multiple organisations, with key focus areas being on governance, outsourcing oversight, design and implementation of processes and controls, operational risk mitigation and regulatory compliance. She is able to understand the challenges that regulated firms might face and utilises her own experience to help firms navigate complex scenarios.
Advisory Director, Square 4
Nicky leads the Client Assets Team at Square 4 and is responsible for overseeing all work in the areas of client assets and financial crime compliance...
Nicky leads the Client Assets Team at Square 4 and is responsible for overseeing all work in the areas of client assets and financial crime compliance, outsourcing and third party management as well as regulatory transactions including authorisations, variation of permission applications and changes in control. She leads on reviews and health checks, provides subject matter expertise to in-house teams and designs processes and controls for firms. She has worked with firms to prepare for and provide support throughout CASS audits, supported remediation and change projects and has led skilled person review teams.
Nicky has 25 years financial services compliance experience with 17 of those years spent providing regulatory consultancy. She has worked with all types of firm, from start-ups to multinational corporations. She has broad experience of general compliance matters, outsourcing and governance and extensive financial crime compliance experience. For the last 11 years, Nicky has focussed heavily on client assets compliance and has deep technical knowledge and wide-ranging experience on the topic.
Square 4 was founded with the vision to support people and businesses grow and thrive.As an organisation, we were founded with the mantra of providing...
Square 4 was founded with the vision to support people and businesses grow and thrive.
As an organisation, we were founded with the mantra of providing an unrivalled level of interaction – service and expertise, supporting firms across a diverse and changing regulated agenda. We are not simply another outsourced service provider. We work in partnership with our clients to drive critical regulatory business change across our core service lines.
We pride ourselves on the diversity of clients that we support:
All payments and e-money firms, although it’s less likely to be of interest to firms that also have deposit-taking permission.
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