What does the Clients’ Assets and Client Money Rules (Client Assets source book CASS) sit outside of?
COBs and MiFID
What are the 4 key points of the CASS?
Explain Fiduciary duty in terms of CASS
o Custodians under a fiduciary duty to act in the best interests of their clients
Explain Custody of clients’ assets in terms of CASS
o Custody rules designed primarily to restrict the co-mingling of client and firm assets
Explain use of clients’ assets in terms of CASS
o A firm most not enter into securities-financing transactions (e.g. stock lending or repurchase agreements) unless:
Explain Reconciliation of clients’ assets in terms of CASS
o As often as is necessary; and
o As soon as reasonably practicable after reconciliation date