CASS oversight Full Time

·      Job Title: CASS Oversight (Non‑SMF)

·      Reports to: Compliance Officer and Chief Operations Officer

·      SMCR: Non‑SMF role (provides support and assurance to Senior Managers holding prescribed responsibilities)

·      Firm profile: Medium CASS Firm; MIFIDPRU investment firm; Category 2 LME member; LME Clear clearing member

Role Purpose

The CASS Manager is responsible for the design, operation, oversight, and evidencing of all Client Assets (CASS) arrangements across the firm. The role ensures the firm can clearly demonstrate compliance with FCA CASS requirements, particularly in relation to LME exchange‑traded and LME Clear‑cleared activity.

The role provides subject‑matter leadership, governance, and assurance over client money and client assets, supporting the Compliance Officer and Chief Operations Officer, and enabling Senior Managers to discharge their regulatory responsibilities effectively. The role does not hold an SMF but operates as the firm’s accountable CASS expert.

Reporting Lines

Primary reporting: Compliance Officer and Chief Operations Officer

Key relationships:

·      Senior Manager with ultimate CASS responsibility

·      Finance

·      Operations and Clearing

·      Risk and ICARA owners

·      External CASS auditors and regulators

Key ResponsibilitiesCASS Governance Framework: Design, own, and maintain the firm’s end‑to‑end CASS governance framework, including:

1.      CASS policies and procedures

2.      Process narratives and control documentation

3.      Management Information (MI) and escalation routes

4.      Audit and regulatory evidence packs

5.      Maintain a single, coherent CASS rule mapping linking: FCA CASS rules → firm policy → operational process → key controls → evidence

6.      Ensure clear allocation of responsibilities across first and second line functions, with defined escalation and Senior Manager oversight.

7.      Support senior management committees with clear, accurate CASS MI, analysis, and risk insight.

Client Money and Client Assets Oversight (CASS 6 & 7)

·      Oversee all aspects of client money and client asset arrangements, including:

o  Initial and variation margin

o  Excess collateral

o  Client clearing‑related cash balances

·      Ensure correct segregation, safeguarding, and trust status of client money in line with FCA rules.

·      Maintain oversight of:

o  Client money acknowledgment letters

o  Client disclosures and contractual documentation

o  Any title transfer collateral arrangements, ensuring appropriate documentation and compliance

·      Provide specialist oversight of LME and LME Clear structures, including:

o  Omnibus and segregated client account models

o  Margin, settlement, and default fund flows

o  Protection of client assets in insolvency scenarios

Client Money Calculations and Reconciliations

·      Oversee and review:

o  Daily client money requirement calculations

o  External client money reconciliations

o  Internal custody reconciliations

·      Ensure reconciliation processes are:

o  Performed at the correct regulatory frequency

o  Independently reviewed

o  Fully evidenced with timestamps, sign‑off, and audit trails

·      Ensure reconciliation breaks are:

o  Promptly investigated

o  Escalated in line with tolerances

o  Resolved and documented appropriately

·      Maintain historic records in accordance with CASS record‑keeping requirements.

CASS Breaches, Escalation and Regulatory Notifications

·      Identify, assess, and document:

o  CASS breaches

o  Near‑misses

o  Control weaknesses

·      Own and maintain the CASS breach log, ensuring:

o  Root cause analysis

o  Client detriment assessments

o  Clear remediation actions and timelines

·      Coordinate and support timely FCA notifications relating to CASS issues, ensuring accuracy, consistency, and completeness.

·      Track remediation actions to closure and provide assurance to senior management.

Oversight of Third‑Party and Outsourced Arrangements

·      Provide CASS oversight of all relevant third‑party relationships, including:

o  LME Clear

o  Clearing banks

o  Custodians and tri‑party collateral agents

·      Verify:

o  Appropriate due diligence is conducted and documented

o  Contractual protections are in place

o  Service levels, controls, and reporting are regularly reviewed

o  Ongoing monitoring is evidenced

Audit, Regulatory Engagement and Assurance

·      Act as the primary operational point of contact for CASS in relation to:

o  External CASS audits

o  FCA supervisory engagement

o  Skilled person (s166) reviews, where applicable

·      Maintain a comprehensive CASS audit‑ready pack, including:

o  Rule mapping

o  Policies and procedures

o  Process documentation

o  MI, reconciliations, and sample evidence

·      Ensure the firm can clearly demonstrate:

o  Effective control design

o  Effective control operation

o  Appropriate management oversight and challenge

Change Management and ICARA Integration

·      Assess and provide formal input on the CASS impact of change, including:

o  New products or services

o  Changes to clearing structures or account models

o  System, process, or operating model changes

·      Contribute to the firm’s ICARA, including:

o  Client asset harm and stress scenarios

o  Wind‑down and resolution planning relating to client money and assets

·      Ensure CASS risks are proactively identified and integrated into wider risk and governance frameworks.

Skills, Knowledge and Experience

1.      5+ years as a CASS senior associate or manager preferably within an LME Firm

2.      Extensive hands‑on experience managing CASS for an investment firm, including CASS 6 and CASS 7.

3.      Strong knowledge of:

a.      FCA CASS Rulebook

b.      MIFIDPRU firms

c.      Exchange‑traded and cleared derivatives

d.      LME and LME Clear operational and collateral models

4.      Proven experience engaging with:

a.      External auditors

b.      FCA supervisors

c.      Senior management and governance committees

5.      Ability to translate complex regulatory requirements into practical, well‑controlled operational processes.

6.      Strong documentation, evidencing, and audit readiness skills.

7.      Strong communication skills.