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The FSA has proposed changes to CASS 6 & 7, ‘Custody Rules’ and ‘Client Money Rules’ respectively. The FSA believe that the only types of firm that these changes will impact upon are spread betting and CFD providers which use certain provisions to remove retail clients’ monies from client money protection. The ‘title transfer collateral arrangements’ (TTCA) rules in CASS 6 & 7 mean that neither the custody rules not the client money rules apply when a client transfers full ownership of a safe custody asset or client money to a firm to cover future, actual or contingent obligations. The proposal is that these sort of arrangements will not be allowed in respect of retail clients. As such, firms currently using TTCA with retail clients will either have to consider the feasibility of re-categorising them as elective professionals or else retain them as retail clients and segregate their money and assets accordingly in line with the requirements of CASS 6 & 7. Such firms will also have to consider whether there is any restriction on holding client money on their Part IV permissions. The FSA also comment (s8.18) that some spread betting and CFD providers are incorrectly using the ‘money due and payable to the firm’ provisions (see CASS 7.2.9) inappropriately. The proposed new rules can be found in Appendix 8 of the QCP.

CASS & Safeguarding Services

Protecting client money and assets is a core regulatory obligation and an area of increasing supervisory focus. Whether you are an investment firm, payment institution, or e-money institution, maintaining robust safeguarding and CASS arrangements is essential to meeting regulatory expectations and demonstrating effective governance.

At Complyport, we help firms assess, strengthen, and maintain their client asset and safeguarding frameworks. Our specialists provide practical, tailored support across regulatory readiness assessments, assurance reviews, policy development, and staff training, helping firms identify gaps, enhance controls, and navigate evolving regulatory requirements with confidence.

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expertise
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solutions
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confidence
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Years of
Excellence
1,500+
Successful
Authorisations
1,000+
Active Firms
Receiving Support
8 Lots
FCA/PRA Skilled Person & Consultancy Panel

Our Services

CASS 15
Gap Analysis

With the introduction of the new CASS 15 safeguarding regime, Electronic Money Institutions (EMIs) and Payment Institutions (PIs) must assess whether their existing safeguarding arrangements, governance structures, policies, procedures, and record-keeping frameworks meet the enhanced regulatory requirements. Complyport's CASS 15 Gap Analysis provides an independent assessment of your current safeguarding framework against the new rules and regulatory expectations. We identify areas requiring enhancement and provide a comprehensive report containing detailed findings, practical recommendations, and a roadmap to support implementation and regulatory readiness.

CASS & Safeguarding
Framework Review

A robust safeguarding framework is essential for protecting client money and demonstrating effective governance and oversight. Our CASS & Safeguarding Framework Review assesses the effectiveness of your firm's safeguarding arrangements, including governance structures, risk management processes, reconciliations, controls, policies, procedures, and books and records. The review helps firms identify weaknesses, strengthen controls, and ensure their client asset and safeguarding arrangements remain aligned with regulatory requirements and industry best practice.

Pre-Audit Safeguarding
Health Check

As regulatory scrutiny of safeguarding arrangements continues to increase, firms should ensure they are prepared for independent review and audit requirements. Our Pre-Audit Safeguarding Health Check provides an assurance-style review of key safeguarding controls, customer fund identification processes, reconciliations, governance arrangements, and supporting documentation. This enables firms to identify and remediate issues before a statutory audit or regulatory review, reducing the risk of findings and supporting a smoother audit process.

Policy Review &
Drafting

We review, update, and draft CASS and safeguarding policies and procedures to ensure they reflect current regulatory requirements and best practice. This includes safeguarding methodologies, governance frameworks, reconciliation procedures, escalation processes, resolution packs and record-keeping arrangements.

Training &
Development

Our tailored training programmes help staff, senior management, and boards understand their responsibilities under the CASS and safeguarding regimes. Training can be customised to your firm's business model and regulatory obligations, ensuring individuals have the knowledge and practical skills required to maintain ongoing compliance.

Why Choose Complyport?

Specialist Expertise

Deep regulatory knowledge and hands-on experience across CASS and safeguarding frameworks.

Practical & Tailored

Solutions designed around your business model and regulatory obligations.

Proactive Support

Identify and address issues before they become regulatory findings.

Trusted Partner

Ongoing support to help you maintain compliance and strengthen governance.

Industries We Support

Investment
Firms
Payment
Institutions
E-Money
Institutions
Banks &
Lenders
Broker-Dealers
& Intermediaries

What Our Clients Say

“

Complyport provided invaluable support in reviewing and enhancing our safeguarding arrangements. Their practical approach and deep regulatory knowledge gave us confidence ahead of our audit.

Chief Compliance Officer, Payment Institution

Meet Our Specialists

Alla Konnikov

Alla Konnikov

Managing Director

Former regulatory solicitor with over 15 years’ experience in regulatory compliance, risk and governance. Specialist in financial services regulation and executive training.

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James Borley

James Borley

Director, Payment Services
Compliance

23 years of regulatory experience at the FCA, including serving as PSD2 Accountable Executive and senior in-house compliance roles. An active industry association member, he now provides expert regulatory consulting across the full spectrum of payment services.

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Ready to Strengthen Your
CASS & Safeguarding
Framework?

Speak to our specialists to discuss how we can support your regulatory readiness and ongoing compliance.

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Contact us for assistance

Looking for Compliance Support?

First time getting in touch?

Whether you are applying for regulatory authorisation in the UK, EU, UAE or another jurisdiction, responding to new requirements, or in need of ongoing compliance support,  our team is here to help.

Complete the form on the right, and we will get back to you shortly.  

Looking for Compliance Support?

First time getting in touch?

Whether you are applying for regulatory authorisation in the UK, EU, UAE or another jurisdiction, responding to new requirements, or in need of ongoing compliance support,  our team is here to help.

Complete the form on the right, and we will get back to you shortly.