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.
SM&CR training
Alistair MacDougall Compliance FCA, SM&CR
During a recent workshop, the FCA commented on SM&CR training. They do not believe that some e-learning or short generic training meets their requirements. We believe that this is primarily a reference to the need for all staff to understand the intention of the SM&CR to move firms to a culture of accountability at all […]