The requirement to create and maintain a CASS Resolution Pack (CASS RP), formed a key plank in the FCA’s review of the client assets regime in the UK. It requires each firm which is subject to CASS Chapter 6 (Custody rules) or Chapter 7 (Client money rules) to collate certain information regarding its handling of client money and safe custody assets that would be of use to an insolvency practitioner in the event of the firm’s failure. The purpose of the rules is to facilitate the return of client money and safe custody assets more quickly than is currently the case.
CASS RP and MiFID II
Having been in force since October 2012, most UK firms holding client assets are very familiar with the CASS RP requirements. However, there is considerably less awareness of recent developments which would lead to the introduction of similar legislation at a European level.