In a Twitterview which took place June 19th, DerivSource’s Julia Schieffer quizzed Michael Beaton, managing partner at Derivatives Risk Solutions, about new FSA CASS RP rules and how firms can start preparing their CASS Packs to meet the upcoming October deadline. Read on for more on this new rule. And If you missed this Twitterview, you can see the Q&A below or search the hashtag #CASSRP on Twitter to see the full Q&A and get involved in the conversation.
Q: DerivSource: What is the motivation behind this new regulation? #CASSRP
A: Michael Beaton: Primarily the fallout from the Lehman collapse and the fact that Lehman investors are yet to see the return of their money #CASSRP
Q: DerivSource: So, what is the purpose of the new CASS Pack rules? #CASSRP
A: Michael Beaton: To facilitate the return of client money more quickly than is currently the case #CASSRP
Q: DerivSource: What is a CASS Pack exactly? What is included in the CASS pack? #CASSRP
A: Michael Beaton: A collection of CASS-related documentation and other information which is of use to the administrator of a failed firm #CASSRP
Q: DerivSource: Who must comply with the new #FSA #CASS Pack rule? #CASSRP
A: Michael Beaton: Broadly speaking, all investment firms which are subject to CASS Chapters 6 or 7 (Custody Rules or Client Money Rules) #CASSRP
Q: DerivSource: October is a deadline for CASS? What specifically do firms need to have ready by this date? #CASSRP
A: Michael Beaton: The CASS RP must be entirely complete. Procedures must also exist to ensure correction of inaccuracies w/i 5 business days
#CASSRP
Q: DerivSource: What are the challenges firms face in creating CASS Packs? #CASSRP
A: Michael Beaton: Finding documentation, understanding key internal CASS dependencies and consequences and keeping the #CASSRP up-to-date #CASSRP
Q: DerivSource: How will firms maintain CASS RP? #CASSRP
A: Michael Beaton: A scalable solution and robust policies are vital in minimising the burden implied by the 5 BD CASS RP updating obligation #CASSRP
Q: DerivSource: Creating & maintaining CASS RP sounds labor-intensive. Are there any ways firms can expedite this process (i.e. use technology?) #CASSRP
A: Michael Beaton: It is. Rapid assimilation of CASS RP into BAU is vital. Fortunately, #CASSRP is well suited to capture within a database #CASSRP
Q: DerivSource: What next for CASS #RRP beyond October? #CASSRP
A: Michael Beaton: The #FSA plans to extend #CASSRP to CASS 5 firms but CASS RP itself is just part of a wider FSA review of the UK CASS regime #RRP #CASSRP
Q: DerivSource: Do you have any advice for firms preparing to comply with new CASS RP regulation today? #CASSRP
A: Michael Beaton: CASS RP involves factors beyond a firm’s direct control e.g. a need to renegotiate supplier contracts – plan to start now. #CASSRP
Did you miss our #CASSRP twitterview? Search #CASSRP for full twitterview and follow @MichaelBeaton1 and @DerivSource on Twitter to keep in the loop.
