COVID-19 and the impact on FCA-regulated CASS audits

The latest in a stream of published guidance for auditors reeling from the seismic impact of the COVID-19 lockdown on their work concerns client asset (CASS) audits for FCA-regulated business including brokers, asset managers and investment advisory firms.

Last week, the FCA published its current thinking on the queries relating to CASS audits and coronavirus that it has received from auditors and firms. The brief advice covers practical issues such as:

• delays in banking client money cheques sent to unmanned offices;
• inability to physically verify safe custody assets for CASS 6 reconciliations;
• segregation, diversification and even size classification changes that result from a higher than normal amount of client money being held; and
• difficulties in reporting, both regarding the routine CASS audit report and notifications under whistle-blowing duties.

There are no automatic waivers or deadline extensions being offered. Instead, the FCA encourages regulated firms and auditors to talk to it about any difficulties they encounter. You can contact the FCA most effectively on such issues by emailing CASSAudit@fca.org.uk.