Controlled Function CF10a
As mentioned in previous Regulatory Roundups e.g. issues 23 & 28, CASS medium and large firms (see article above on CMAR for criteria) need to allocate the new function of CF10a (CASS operational oversight function) to a director or senior manager of a firm. Although the rules do not come into force until 1 October, firms can apply from 1 May.
Applications for the CF10a function have to be made by post and not ONA (see Regulatory Roundup 28 re ONA systems problems and new controlled functions). Further details, including guidance notes on the completion of the application form, can be found from the FAQ link.
Note that small CASS firms (generally holding less that £1m in client money but see CASS 1A.2.7R for definition) do not need to apply for a CF10a but they must allocate an individual to have CASS operational oversight. This individual must be a director performing a significant influence function (SIF) or a senior manager performing a SIF responsibility. The individual will also be responsible for reporting to the firm’s governing body in respect of that oversight.