s166 Skilled Person Reports & CASS Compliance - A Practical Guide

Introduction

The FCA still regards compliance with the Client Assets (‘CASS’) regime as a strategic priority with high standards of CASS governance and oversight, including a robust three lines of defence model.

Where the FCA sees behaviours from firms which lead it to consider that the firm is not taking its CASS compliance obligations seriously, or if it identifies significant CASS failings, it has the power to require a firm to commission a Skilled Person’s report under s166 of the Financial Services and Markets Act 2000 or to restrict a firm’s activities through use of VREQs (Voluntary Requirement).

Continued non-compliance and regulatory failings may also expose a regulated firm to enforcement action.

This webinar is suitable for lawyers who advise regulated firms and those responsible for CASS governance and oversight to understand the FCA’s approach to CASS, as well as how it uses these powers.

The webinar will also discuss what firms can do to reduce the possibility of facing a s166 Skilled Person report or enforcement action.

The FCA has also demonstrated that it expects those Senior Managers who are taking on the Prescribed Responsibility for Client Assets to fully understand the CASS requirements of their firms.

Recent Special Administrations of several firms are likely to bring increased focus on those with CASS responsibilities.

What You Will Learn

This webinar will cover the following:

• The FCA’s current supervision strategy for CASS and expectations of Senior Managers
• Why the FCA uses the s166 Skilled Person reports and how this interacts with the enforcement process
• The possible consequences of serious non-compliance of the CASS rules
• The process by which firms are required to commission a s166 Skilled Person report
• How firms can avoid s166 Skilled Person reports

This pre-recorded webinar will be available to view from Monday 15th September 2025

Alternatively, you can gain access to this webinar and 1,700+ others via the MBL Webinar Subscription. Please email webinarsubscription@mblseminars.com for more details.