FIDE CONSULTING - CASS 15 Readiness Assessment

Safeguarding Institutions

CASS Readiness assessment checklist by Fide Consulting

Firm Name

This CASS readiness assessment checklist provides a structured framework to evaluate your firm's preparedness for change. It identifies readiness gaps and enables the firm to tailor support, training, engagement strategies and resources accordingly.

Guidance on populating the priority level for action section.

Low - for areas with straightforward requirements and minimal technical complexity, where quick wins can be achived without the need for external guidance to implement the changes.

Medium - for areas where requirements are straightforward to intepret, but where deploying changes will require an investment of time and internal resources

High - for areas where interpreting the requirements involves technical complexity or where significant investment in resources and engagement of external subject matter experts is necessary.

Instructions

You can save your progress at any time and return later to complete the readiness assessment checklist. After submitting, you’ll still be able to make edits if needed. A PDF copy of your submitted checklist will be automatically sent to your e-mail as an attachment.

⚠️ Please not this checklist should not be used as a comprehensive listing of the CASS rules, the onus is on firms to do a detailed review of the rules.

Governance

Rows	Yes	No	N/A	Priority level for action
Did the firm appoint safeguarding oversight officer appointed with a clear reporting line to a governing body?
Is a CASS 15 governance committee established and are there MI packs completed for presentation at the committee?
Do you have a clearly defined safeguarding framework with roles and responsibilities clearly defined?
Do you have a safeguarding training program to enhance knowledge and awareness across the organisation?
How are the three lines of defence involved when it comes to compliance with safeguarding regulation?
Are you in scope of an audit, i.e. did you hold funds in excess of £100 000 during the year?
If so, have you appointed an independent auditor?

Information systems and technology

Rows	Yes	No	N/A	Priority level for action
Do you have independent books and records to record client entitlements i.e to accurately reflect client entitlements and safeguarded funds, separate from third party records?
Are the IT systems subject to appropriate IT general and application controls?
If you use any excel spreadsheets or datebases to perform key functions such as reconciliations or calculations, do you have end user computing controls such as passwords or access restrictions in accessing these?
Do you have change management process in place to consider the downstream impact on calculations or reconciliations when new systems are introduced or changes made to front/middle/back office systems?

Operational procedures and controls

Rows	Yes	No	N/A	Priority for action
Do you have a safeguarding policy, that outlines the firms standards specific to safeguarding compliance?
Is there a process in place to ensure that the safeguarding policy document is reviewed and kept up to date?
Do you have operational procedures in place for key processes such as reconciliations, due diligence, CASS RP etc?
What process is in place to ensure that these procedure documents reviewed and kept up to date with the current business models?
Do you have a risks and controls matrix mapped against each of the CASS rules in scope?
What process is in place to ensure that the risk and controls matrix is reviewed and kept up to date with any updates to processes and controls?
Do you have a breach reporting and escalating process in place when CASS compliance issues or breaches occur?

CASS rule compliance

Rows	Yes	No	N/A	Priority for action
Do you a CASS applicability matrix, documenting all of the firm's activities and highlighting which are in/out of scope?
Have you documented the flow of funds, its sources and destination, and system(s) in which transactions are recorded?
Are all relevant funds held in designated safeguarding accounts, with appropriate naming convention to include the word ' safeguarding' where possible? CASS 15.2.2R
If you receive mixed remittances, do you have a written policy highlighting your approach? CASS 15.3.2R
If your firm invest in secure, liquid assets (relevant assets) as specified in the CASS 15 handbook, do you have to ensure that policies and procedures to comply with CASS 15.4.6R
If you appointed a third party to manage relevant funds, have you performed due diligence in the appointment? CASS 15.4.8R
Does your firm use an insurance policy or guarantee to protect relevant funds?, If so do have you considered all the conditions under CASS 15.5.4R
If your firm uses third parties for depositing relevant funds, relevant assets, insurance or guarantee, have you performed due diligence and considered the need for diversification? CASS 15.6.1R
Do you have acknowledgement letter (drafted per CASS 15 Annex 1) for each relevant assets and relevant bank accounts your firm has opened with third parties? CASS 15.7.5R
Is you firm not required to carry out an internal safeguarding reconciliation? If so have you documented this and can you provide supporting evidence? CASS 15.8.11R
Does your firm rely on data obtained from third parties to create internal records? If so have you documented that no other method can be employed? CASS 15.8.17R
Does your firm use a non-standard method of internal safeguarding reconciliation. Have you documented this and appointed an auditor to provide an opinion? CASS 15.8.37R
Does your firm mantain a CASS Resolution pack as required under CASS 10A

Date prepared

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