What is the difference between client money and the firm's own money?

Client money belongs to the client and is held by the firm on their behalf, typically under a statutory trust and segregated in designated client bank accounts. The firm's own money is its corporate funds. Keeping the two strictly separate is central to CASS and protects clients if the firm becomes insolvent.

What is the CASS oversight function?

Under SM&CR, firms holding client assets above a certain threshold must allocate the CASS oversight responsibility to a Senior Manager. This function oversees the firm's compliance with the CASS rules, including segregation, reconciliations and the resolution pack, and ensures issues are identified, escalated and put right.

Regulatory & conduct

Client Assets (CASS)

Explain how firms must protect client money and custody assets under the FCA's CASS rules, so they can be returned promptly if the firm fails.

Duration: ~20 min Accreditation: CPD accredited (CII) Last updated: May 2026 Reviewed by: Margaret Hassett

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What is CASS, and why does it matter?

CASS is the FCA’s Client Assets sourcebook. It sets out how firms must protect client money and custody assets so that, if the firm fails, those funds and assets can be identified quickly and returned to clients rather than caught up with the firm’s own estate. Breaches are treated as serious matters.

Who needs CASS training?

This training is for operations, finance, treasury and compliance staff at firms that hold or control client money or custody assets. Because much of the protection depends on disciplined everyday practice, such as segregation, reconciliations and the resolution pack, the people performing that work must understand why the rules exist and what good looks like.

What does CASS training cover?

The course explains the purpose of the CASS regime in plain English. Learners distinguish client money from the firm’s own money, understand segregation and the statutory trust, and recognise the core requirements for reconciliation. It also clarifies the role of the CASS oversight function, where individual responsibility sits and what to escalate.

What does the FCA expect from CASS arrangements?

The FCA’s CASS sourcebook requires firms to segregate client money under a statutory trust, perform accurate reconciliations and maintain a CASS resolution pack. Under SM&CR, firms above a threshold must allocate the CASS oversight responsibility to a Senior Manager who oversees compliance and ensures issues are identified, escalated and put right.

What your team will learn

Explain the purpose of the CASS regime and why it matters
Distinguish client money from the firm's own money
Recognise the core requirements for segregation and reconciliation
Identify the role of the CASS oversight function and what to escalate

What's included

~20 min of focused, scenario-based learning
CPD accredited (CII)
Built-in quiz with a configurable pass mark
Reviewed and kept current with UK regulation
Time-stamped completion records for your audit trail

How it works

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Your team completes it

Learners work through the course at their own pace on any device, finishing with a short assessment that demonstrates understanding.
Evidence it to the regulator

Every completion is time-stamped and retained, so you can prove the right people did the right training at any moment.

Frequently asked questions

What is CASS?: CASS is the FCA's Client Assets sourcebook. It sets out how firms must protect client money and custody assets so that, if the firm fails, those funds and assets can be identified quickly and returned to clients rather than caught up with the firm's own estate. Breaches are treated as serious matters.
What is the difference between client money and the firm's own money?: Client money belongs to the client and is held by the firm on their behalf, typically under a statutory trust and segregated in designated client bank accounts. The firm's own money is its corporate funds. Keeping the two strictly separate is central to CASS and protects clients if the firm becomes insolvent.
Who needs CASS training?: Operations, finance, treasury and compliance staff at firms that hold or control client money or custody assets need CASS training. Because much of the protection depends on disciplined everyday practice, such as segregation, reconciliations and the resolution pack, the people performing that work must understand why the rules exist and what good looks like.
What is the CASS oversight function?: Under SM&CR, firms holding client assets above a certain threshold must allocate the CASS oversight responsibility to a Senior Manager. This function oversees the firm's compliance with the CASS rules, including segregation, reconciliations and the resolution pack, and ensures issues are identified, escalated and put right.