The FCA has issued a ‘Dear CEO’ letter to General Insurance Intermediaries setting out its expectations for maintaining adequate arrangements that safeguard client money especially during the coronavirus (Covid-19) pandemic.
It reminds firms of their obligations to continue to oversee the CASS arrangements. It requires firms to discuss the contents of the letter with the board and agree what further action is necessary to help ensure adequate arrangements are in place, highlighting the following areas:
- application of client money rules to firm’s business model;
- governance and oversight;
- oversight of third parties, including due diligence;
- client money calculations and reconciliations;
- acknowledgement letters for all client money accounts.
You can find further information regarding client assets and coronavirus here.
Conduct Rules Breaches – follow up
Huw Reynolds Compliance Conduct, FCA, Pension, Senior Manager, Update
We wrote recently about the Conduct Rules and, in particular, breaches and notifications . See here. This article is intended to clarify some of the grey around COCON breaches. All of the following is taken from Policy Statement PS 18-14. When is disciplinary action required? When and how a firm decides to undertake disciplinary action […]