CASS Culture: The power of collaboration Nicky Green??

In the 14th edition of the JCR Journal, we speak to Nicky Green about the company-wide impact of a positive CASS culture and the power of collaboration.

All of Nicky's thoughts and opinions below are her own.

Why is a good CASS culture so important to the long-term success of a business?

For a firm with CASS permissions, a positive CASS culture can make a huge difference to the success of the business. It can help make CASS processes work more effectively and efficiently, reducing the likelihood of CASS breaches and increasingly the likelihood that problems will be spotted quickly. Having a CASS culture embedded throughout the organisation can help the business ensure it is positioned to be agile and maximise opportunity. Too many firms hold outdated views that see CASS compliance as being a blocker to business.

What do you see as being the biggest challenges in aligning business growth with good CASS culture?

One of the biggest challenges I see in the firms I work with is a tendency to see CASS compliance and good CASS culture as being at odds with business growth. I often see a ‘them and us’ approach to CASS compliance with the strategic decision makers being disconnected from CASS oversight teams with neither side making enough effort to understand the viewpoint of the other. On the other side of the coin, I’ve worked with firms where an opportunity for strategic change has been identified but those responsible for CASS Oversight have put blockers in the way without explanation.

There will always be cases where a proposed business change would have a detrimental impact on CASS compliance and in extreme cases, a proposed change simply can’t happen. However, CASS teams should always explain the logic behind their decision making in these cases. They can also work with the business to understand what it’s trying to achieve and explore alternative approaches that could be taken that would help achieve it while ensuring CASS compliance. Simply shutting down the discussion can have an incredibly detrimental impact on the relationship between the CASS oversight function and the wider business.

What about Operations – how can a solid CASS culture help a firm achieve operational effectiveness and efficiency?

Operations teams are the engine room of CASS compliance, running the processes, keeping assets safe and books and records up to date. However, a common problem is a disconnect between operational expertise and CASS knowledge. Operations teams invariably have a detailed knowledge of the operational processes and controls they run, having an excellent eye for how those processes can be improved for the benefit of the business. However, in some cases, those operational teams aren’t equipped with the depth of knowledge that would help them understand and articulate what the processes and controls are intended to achieve in CASS terms. In many cases, this is because the CASS oversight team take an approach of instructing rather than collaborating. In my experience, if operations team are involved in the development of CASS processes and understand what processes are intended to achieve, they often identify areas where improvements and efficiencies can be made. Most importantly though, it can better equip those teams to spot when something might go wrong with a process, so that action can be taken before a breach happens.

What would you say are essential elements of maintaining a good CASS culture that would enable a firm to foster collaboration within the business?

? Tone from the top

As with any aspect of the culture of a business, the tone from the top is the key. If the senior management of a business are dismissive of the importance of CASS compliance, that attitude will cascade throughout the business. As a result, you’ll see people within the business being resistant to engaging with CASS oversight teams and in the worst cases, CASS teams will be excluded from conversations on operations and strategy.

? Robust governance

Always a key area of focus to ensure clear lines of responsibility and accountability demonstrating the necessary oversight, risk management and regulatory adherence.

? Training

Making sure that teams receive training that is tailored for the business and the CASS risks it faces is essential. Generic CASS training can be useful to give a foundation knowledge of CASS requirements, but firm-specific training will equip teams to understand the CASS risks they’re managing. It will also give the whole business an understanding of the overall CASS picture for the firm, enabling them to understand the role that other teams play in the control framework and importantly, how teams can impact each other positively and negatively.

? Breach and incident reporting

Encouraging team members to be open and honest in reporting of breaches and incidents is essential in making sure that you’re on the front foot with remediation. Whilst there will inevitably be occasions where more training is needed or where processes need to be improved, but I think a no-blame culture is essential in ensuring everything gets reported and remediated in the right way.

Does AI/technology have a part to play in supporting CASS culture?

Whilst I don’t claim to be an expert in technology, I think the developments in this area are exciting. We’ve already seen the use of tech as being an integral part of reconciliations, risk mapping and maintenance of resolution packs. The possibilities for the use of AI in this area are limitless, depending on how well the industry embraces it – for example, could the future involve the use of AI to run discrepancy management processes? We can’t forget the possible impact of distributed ledger technology either – could that be used to make CASS record keeping more efficient and accurate?

What would be a useful exercise for business leaders to consider measuring CASS culture across the team/business?

The key thing I’d encourage business leaders to do is talk to the business. Do they really ‘get’ what CASS compliance means for the firm? Don’t just talk to team leaders, listen to voices throughout the business to get a true picture. Most importantly, be prepared to listen to ideas and suggestions for how things could be made more efficient, more profitable and more compliant from across the business.

A huge thank you to Nicky for her insight into CASS??

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