CASS & Safeguarding Consulting for Payment and E-Money Firms
We help payments and e-money institutions implement the FCA’s safeguarding and CASS requirements efficiently and defensibly—covering gap analysis, reconciliations, the Safeguarding Resolution Pack, governance/policies, and audit-ready evidence.
Where we help
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CASS 15 & safeguarding gap assessment (PSRs/EMRs vs. new rules)
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Safeguarding policies & governance (Board/SMF oversight, MI, attestations)
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Reconciliations design (daily/periodic, treatment of timing differences)
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Safeguarding Resolution Pack (templates, inventory, third-party confirmations)
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Bank/insurance arrangements & legal opinions (where relevant)
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Operational readiness (processes, systems, data, controls, BAU handover)
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Training & culture (first/second line, SMF responsibilities)
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Audit/external assurance support & remediation
Typical engagement & timeline
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Diagnostic (2–3 weeks): document/request list, interviews, controls walkthrough, gap map and risk-based plan.
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Design (4–8 weeks): policies/procedures, reconciliation model, SRP artefacts, governance/MI, training plan.
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Implementation (4–8+ weeks): pilot runs, evidence packs, issues log, roll-out & handover.
Delivrables
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CASS & safeguarding policy suite and RACI
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Reconciliation methodology & SOPs, exception handling
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Safeguarding Resolution Pack (checklists, registers, third-party letters)
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Governance & MI pack (Board paper templates, KPIs/KRIs)
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Training materials & attestation records
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Audit-ready evidence (walkthroughs, samples, screenshots)
Who we help
Authorised payment institutions, e-money institutions (including small e-money), and credit unions issuing e-money under PSRs/EMRs.
Why Phoenix FSC
Senior practitioners with hands-on post-trade and regulatory change experience; contributors in the securities/post-trade community (including TSSAG membership).
FAQ Q: What is CASS 15? A: A new chapter in the FCA Client Assets Sourcebook that codifies and strengthens safeguarding for payment/e-money firms, including reconciliations, governance and a Safeguarding Resolution Pack. Q: How long does implementation take? A: 8–16 weeks for most firms, depending on data/process complexity and audit scope. Q: What goes into a Safeguarding Resolution Pack? A: Evidence of safeguarding arrangements (bank/insurance), reconciliations, policy set, key contacts, third-party confirmations, mappings and MI—kept up-to-date and retrievable. Q: Can you support our auditors/assurance provider? A: Yes—scope alignment, sample selection, walkthroughs and remediation tracking. Q: Do you provide training? A: Yes—tailored modules for first/second line and SMF holders with records/attestations.