UK Finance commends the FRC for its work on its standard on Providing Assurance on Client Assets to the Financial Conduct Authority (to be referred to in this response as 'the standards?). The standards have had a broadly positive impact on the quality of the audit work, providing a clear framework to the auditors, who typically use the standards as an anchor to derive their own interpretation of the Client Asset (CASS) rules, and their own expectations on how the related issues should be approached.

The standards have also been of significant benefit to firms, providing them with greater visibility as to the process behind audit requirements, a clearer view of CASS applicability, controls and risks, and the general need to meet the FRC standards. However, despite the best efforts of firms, auditors, and other related stakeholders, we have observed that an improved framework has not necessarily resulted in better quality audits in all cases.