CASS responsibilities under the SMCR

While the SMCR does not represent a material shift in the standards expected of Senior Managers, there is a heightened focus on their ultimate responsibility for regulatory compliance within their prescribed area. Kishore Bhindi discusses the CASS Prescribed Responsibility and Certification Function, along with a framework for the reasonable steps Senior Managers should take.

Kishore Bhindi is an associate with lawyers Latham & Watkins in London, where he is a member of the financial institutions industry group. Contact him on kishore.bhindi@lw.com.

The Senior Managers and Certification Regime currently applies to certain Prudential Regulation Authority-authorised firms and will be extended to most other authorised firms on 9 December 2019. This article provides an overview of the interaction between CASS (the Client Assets Sourcebook) and the SMCR as well as, more importantly, some hands-on practical points to consider with respect to managing the risks that arise for Senior Managers in this space.