In this episode
Chloe Curtis has led CASS functions at several firms after time in retail banking, at the regulator and in Big Four consulting. In this episode she takes apart the architecture of a CASS function: what it looks like on paper, what it looks like at 4pm on a Friday, and who stays accountable for client money when the administrator, custodian or platform runs the reconciliation.
Questions this episode answers
Who owns the client money when the administrator runs the reconciliation?
The firm does, always. Outsourcing the task never outsources the regulatory responsibility, and the FCA will ring the firm, not the administrator.
What does outsourcing oversight mean in practice?
It means the firm can evidence, on any given day, that the reconciliation was done, was right and was reviewed. A monthly MI pack filed unread is not oversight.
Is there a CASS control that can never be outsourced?
The decision that the reconciliation is complete and the sign-off that goes with it. Someone inside the firm has to own that judgement.
What does a well-governed CASS function hand its auditor?
A process map that matches reality, a break log with owners and ages, evidence of review and a resolution pack the firm could actually produce on a Friday afternoon.
Get the one-page takeaway
Chloe's five points on outsourcing oversight, on one page, for your next CASS committee.
Timestamps
- 00:00 Cold open
- 03:00 From the regulator to the CASS chair
- 08:00 The CASS function on paper and on a Friday
- 18:00 Who owns the money when someone else runs the rec
- 28:00 Controls that survive contact
- 37:00 The break you couldn't explain
About the guest
Chloe Curtis
16 years in financial services across retail banking, the regulator, Big Four consulting and asset and wealth management, specialising in CASS for over eight of them.
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