FRC Client Assets Standard 2019

The FRC released the revised FRC Client Assets (“CASS”) Assurance Standard on 25 November 2019. This Standard is effective for reports to the FCA with respect to Client Assets for periods commencing on or after 1 January 2020. From our experience, we consider that the Standard has contributed to a significant improvement in the quality and consistency of CASS audits. We also believe that the application of the Standard has contributed to a significant improvement in the understanding and documentation of control processes within regulated firms. 

We generally agree with the changes made by the FRC, and are pleased to see our additional feedback has been considered in a number of areas, including the use of internal audit, reliance on System and Organisation Control (SOC) Reports; and extending the reporting requirements to those charged with governance.

We also welcome the clarity the FRC final published Standard has provided to ensure there are no major changes to the audit scope. They have redrafted to remove and clarify the below proposed areas where we had raised concerns regarding scope increase within our feedback to the consultation:

  • Assurance on the completeness of the firm’s record of breaches; and
  • Implications of applying an ‘insolvency mindset’.

You can see the full text of our response to the consultation here
Go to the FRC website for the Consultation document and the related Impact Assessment
Go to the FRC website for the new FRC Client Assets Assurance Standard

Kim Stainfield

Kim Stainfield | Senior Associate in CASS ARQ, PwC United Kingdom
Profile | Email | +44 (0)7483 327031

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