Our client is a financial services firm that runs systems infrastructure and associated services for equity traders. They are based in London and regulated by the FCA.
The firm approached us in 2012 at the time of consultation for FCA policy statement 14/9. Their challenge was the additional time and cost required for maintenance of the ‘CASS resolution pack’ and the need to evidence the required governance and controls in a more comprehensive way than by using a basic ‘Excel and Word’ approach.
Our client’s business objects were to:
- Save time and money in the production and maintenance of the CASS resolution pack
- Demonstrate comprehensive compliance with the provisions of the CASS handbook
- Produce a value asset that can be used throughout the firm for induction and training
- Obtain a centralised entry-point for the management of the firm’s CASS information
Working closely with the CF10a, we developed the product features that enable our client to:
- Organise their content and data under FCA categories to demonstrate compliance from the outset
- Assign ownership to colleagues to distribute the workload of checks and updates across their firm
- See the status of their resolution pack at any time with a red-amber-green dashboard
- Set attestation frequency per-pack record to send automated reminders to staff prior to next check date
- Keep an audit of views, updates and previous versions
- Create staff teams to focus on certain areas to monitor their upcoming tasks and record status
- Generate the pack in various formats to suit their document management system
Our client can now maintain their resolution pack when content changes with a few clicks and always has the current and previous versions of the pack available, vastly reducing the time and cost required to comply with CASS Handbook Chapter 10. The workflow associated with the pack has been distributed across individuals with CASS roles who can all access a central portal for managing updates and attestations. The firm now has a comprehensive solution to CASS compliance that they can use as the central asset in any CASS full-scope or chapter 10 audit visit.