TISA urges FCA to be more ambitious with CASS regime modernisation, as proposals risk increasing complexity and raising compliance costs with little benefit for consumers
Today, The Investing and Saving Alliance (TISA) has responded to the Financial Conduct Authority (FCA) consultation CP25/37: Targeted Clarifications of Handbook Materials, which proposes changes to the Client Assets Sourcebook (CASS)
The FCA consultation is intended to clear up outdated and overlapping rules, introduce greater proportionality, and make requirements easier to understand – particularly for smaller firms.
TISA and its members support these aims and agree that changes to CASS 6 and CASS 7 are needed to improve clarity, flexibility and predictability in how firms safeguard client money and
assets.
However, TISA warns that some of the proposals, as currently drafted, would do the opposite – increasing complexity, raising compliance costs and making the rules harder to interpret, without improving the protection of client assets
Sophie Legrand-Green, Head of Policy at TISA, said:
“Consumers need to be confident that their money and investments are properly protected, and that depends on clear, workable rules for firms. We support the FCA’s aim of simplifying and modernising the client assets regime, but some of the proposals as drafted would add complexity and cost without improving protection. There are simpler ways to achieve the FCA’s objectives while keeping consumer safeguards strong, and we encourage the FCA to take a more ambitious approach”
In its response, TISA supports changes that would allow firms to resolve long-standing due diligence record-keeping issues and agrees in principle to proposals that would give firms more flexibility when monthly custody statements are not available. However, TISA highlights that the detailed drafting introduces ambiguity and additional documentation requirements that are not aligned with the consultation’s stated aims.
TISA also opposes proposals to insert explicit Consumer Duty compliance requirements into the CASS rulebook, noting that firms already understand and comply with their obligations under the Duty. Duplicating these requirements within CASS risks adding complexity rather than improving outcomes and contradicts the FCA’s wider work to remove duplication from the Handbook in light of the Consumer Duty.
ENDS
Notes to editors
• For a copy of the full consultation response, please contact tisa@tendoconsulting.co.uk
• TISA is a not-for-profit membership organisation committed to improving the financial wellbeing of all UK consumers by working collectively with the financial services industry to deliver solutions and champion innovation, for the benefit of people, our industry, and the nation.
• TISA has approximately 270 member firms involved in the supply and distribution of savings and investment products and associated services. Members include the UK’s major investment managers, retail banks, online platforms, insurance companies, pension providers, distributors, building societies, wealth managers, third party administrators, FinTechs, financial consultants, financial advisers, industry infrastructure providers and stockbrokers.