2A first brokerage is reminded of the additional obligations of CASS 9.3.1R applicable to premium brokerage contracts. For corporate customers, the FCA approach, if it results in increased restrictions on the use of TTCAs by businesses, would have both benefits and costs. If a company requires its customers to hold cash and assets outside of a TTCA, this will reduce the credit risk customers have for the business, but the higher costs the business would incur will likely be passed on to its customers. In addition, a company that does not offer money or asset custody to its clients may require its clients to undertake administrative procedures, such as. B the active transfer of the company`s cash and surplus assets. CASS 7.11 deals with the TTCA waiver of corporate money requirements. (CASS 6.1.6D contains equivalent provisions on deposit assets, such as for example. B titles.) CASS 7.11.4R provides the following provisions: TTCAs are an exception to the normal obligation for companies holding customers` money to offer cash protection to that customer in cash and to hold securities of customer value in the same manner. TTCAs are permitted to the extent that the company holds the cash or securities as collateral for the bonds that the customer owes or is likely to owe to the company. In January 2018, MiFID II introduced changes to the provisions of the FCA Client Asset Sourcebook (CASS) for TTCAs. The CEO of Dear Letter is the first letter of its kind to focus on TTCAs since the new provisions. No one who really knows how it works will give too many details, but the other answers cover it. 121 and 135 operators participating in the CASS program can jumpseat.
Not all airlines/operators are members. Karen has over 31 years of experience in the financial services industry and has been a consultant since 1999. Orders placed include assistance in the development and implementation of operational processes, including customer money procedures; Selection and implementation of subcontracting suppliers; operational transformation and strategic advice on supply. She has worked for a large number of companies, including platforms and their software providers, asset managers, asset managers and outsourcing providers. Other experiences include reviewing, benchmarking and selecting systems for front-end offices and operational areas; review of business processes and design of the operating model; and regulatory support, audits, rehabilitation and training in the areas of cass, RDR, ISA management, MiFID and TCF. In addition to her consulting experience, Karen COO was a retail broker, responsible for internal custody, systems, settlement and all other aspects of client care. She was also responsible for the client`s private administration with an asset manager and held various supervisory and management positions at the London Stock Exchange, including an after-sales service role covering all small to medium-sized brokers and all associated software houses. Ongoing review of your company`s structure and processes to minimize the risk of non-compliance. Our specialized and practical advice helps you ensure that you implement the necessary systems and controls..
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