Implementing CASS 15: Safeguarding Operations for Payment & E-Money Firms

Introduction

The FCA’s new safeguarding regime introduces more detailed operational expectations for payment and e-money firms, including reconciliations, oversight of safeguarding institutions, formal resolution documentation and independent safeguarding audits.

For many firms this represents a significant operational shift from existing safeguarding practices.

This practical session focuses on how firms can implement the operational elements of the new regime and design safeguarding frameworks that meet the FCA’s expectations.

What You Will Learn

This live and interactive course will cover the following:

• Designing a safeguarding framework
• Structuring safeguarding arrangements under CASS 15
• Choosing appropriate safeguarding methods
• Oversight of safeguarding banks and safeguarding institutions
• Safeguarding accounts and safeguarding institutions
• Requirements for safeguarding accounts
• Eligibility of safeguarding institutions
• Diversification expectations
• Acknowledgement letters and bank confirmations
• When funds must be safeguarded
• When funds become relevant funds
• Segregation timing requirements
• Operational challenges in payment flows
• Safeguarding reconciliations in practice
• Internal safeguarding reconciliations
• External safeguarding reconciliations
• Understanding reconciliation days
• Identifying and resolving discrepancies
• Managing safeguarding discrepancies
• Managing shortfalls and excess balances
• Escalation and governance processes
• Regulatory notification considerations
• Safeguarding records and documentation
• Maintaining safeguarding records
• Documentation required to evidence compliance
• The safeguarding resolution pack
• Purpose of the resolution pack
• Key documentation requirements
• Maintaining and updating the pack
• Safeguarding reporting and audit readiness
• Preparing for the independent safeguarding audit
• Evidence and documentation expectations
• Managing regulatory reporting and notifications
• Implementation and operational readiness
• Practical implementation challenges
• Aligning safeguarding processes across compliance, finance and operations
• Demonstrating compliance to regulators and auditors

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.