TISA CASS Survey Results
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TISA SURVEY ON CASS COMPLIANCE

October 2024

TISA’s CASS survey was conducted in partnership with fscom and sought out to gather insights from the CASS community about key areas of interest related to compliance and challenges of CASS. We had 105 respondents for the survey, which was carried out from July to September 2024. This report summarises the survey results in infographic form, detailing any standout commentary from our respondents.

This targeted survey looked at some specific touchpoints with complimentary regulations, Consumer Duty and the Alignment of the Payment Service & EMI safeguarding regime, aiming to assess any significant changes occurring  across the industry. 

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SURVEY HIGHLIGHTS

While Consumer Duty changes have been notably impactful, the survey findings highlighted that:

  • Firms tend to view each regulatory regime in isolation, only considering cross-regulation impacts when specifically required.
  • Many firms expressed the need for more detailed guidance on achieving synergy across different regulatory areas.
  • A key theme from the responses was the demand for improved audit alignment and clarity, particularly in complex areas of the CASS rules. Recent high-profile challenges and upcoming safeguarding audits being brought into FRC standards were viewed positively, yet the survey revealed concerns about inconsistencies in audit interpretations, often referred to as audit ‘house views.’

On a positive note, firms are recognising these challenges and are eager to collaborate to align CASS audit findings and outcomes across the industry. Our survey partner, fscom, has been instrumental in assisting firms with audit preparation and addressing audit findings, highlighting the complexity faced by both firms and auditors in navigating these evolving regulatory landscapes.

 
The survey results indicate that there continues to be evolving and inconsistent interpretations of certain areas of the handbook, exacerbated by the changing regulatory and technological landscape. We would like to see a focus on how CASS can remain fit for purpose.”
Lisa Laybourn
Policy Director, TISA
The survey results indicated demand from firms requiring more specific guidance across handbook areas and a number of requests for audit consistency and clarity alongside. These are subjects that may benefit from further focus to help mitigate any residual challenges.”
Julie Tuffrey,
CASS Expert, fscom
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LOOKING AHEAD

Thank you for taking the time to read our report. We hope you found it insightful.

What’s apparent, is that this topic would benefit from further analysis and synergy to try to mitigate any residual challenges and is an area we do intend to discuss further as part of both TISA’s next CASS Committee meeting and the fscom CASS advisory group.

This will help form part of TISA’s dialogue with the regulator in the coming months and if you would like further details on that, please do not hesitate to get in touch.

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