Now that we’re all firmly settled back into work for a new decade, we thought it would useful to take a look at the key themes / trends we think will be big in CASS in 2020 and beyond:
If you are wrapping up a 2019 audit over the next few months we advise planning ahead to ensure you take advantage of the changes for the 2020 audit.
Released in November 2019 and applicable to periods starting on or after 1st January 2020, the final text reflects feedback given by firms on the earlier draft and there are no major changes to scope of the ‘audit’. There remains the possibility of using SOC reports for assessing outsource providers and knowledge of findings from other work undertaken with the firm.
We advise keeping an eye out for FCA messaging on this topic and getting ahead by ensuring any automation currently in place is fully documented.
It is likely the regulator will be taking an increasing interest in the elements of CASS operations that have been automated. Our 2019 survey reported that 46% of firms are using of thinking of making use of robotics in CASS-related processes. We have also found some were unaware that automation had been introduced for them either by an outsourced provider or a firm-wide robotics programme. This rapid increase (up from 22% in 2018) is sure to draw attention.
- Maturing Child Trust Funds (CTFs)
In our opinion it is best to start planning for how this might work operationally and to reach out to as many impacted parties as possible well in advance.
What will happen when the first recipients turn 18 in September 2020? At time of writing the government are still analysing feedback on the draft regulation consultation that closed in August 2019. It has been suggested that if a firm does not receive instructions, either the CTF will carry on or move into a cash ISA (even if CTF is stocks and shares). There has been a change of government since the consultation closed so those who offer this product will need to keep an eye out. We need to get CTFs done!
Be on the lookout for EU withdrawal plans in February
We nearly made it to the end of this blog without mentioning EU withdrawal. Clearly there is a new wider dynamic in 2020 with a change of UK government. For those that passport into the UK from the EU CP 18/29 gave the details of the temporary permissions regime should the EU treat the UK as a ‘third country’ in the event of a clean break. It looks almost certain now that this could not happen now until 31 December 2020 if at all. The FCA has said it will update post 31st January 2020.
We hope to see some of you at the Infoline CASS conference on Wednesday 25th March 2020. Emad Aladhal from the FCA will be giving the keynote, and we’ll be presenting an overview of the themes and trends observed in our annual CASS survey.
Have a good start to the year!