CASS 7 vs CASS 15: Hiring the Right Client Money Skills

“CASS experience” is one of the least useful phrases in a regulated finance job specification, because it describes several genuinely different jobs. A candidate who has run client money reconciliations at an investment firm under CASS 7 is not interchangeable with one from a debt management firm under CASS 15, or an insurance broker under CASS 5 — the rules differ, the calculations differ, the failure modes differ, and the audit differs. Employers who specify CASS generically get shortlists containing the wrong experience and only discover it in month two. This guide sets out what each regime covers, why the distinction matters when hiring, and how to test for the right one.

For the authoritative position, the rules themselves sit in the FCA Handbook’s CASS sourcebook. This guide is a practical account for employers and finance professionals, not a compliance opinion.

The three regimes most UK firms encounter

CASS 5 — insurance client money. Applies to insurance intermediaries: brokers, MGAs and those handling premium and claims money. Distinctive features include the risk transfer concept, where money held as agent of the insurer may not be client money at all, non-statutory and statutory trust arrangements, and the interaction with binder and delegated authority accounting. The calculation is unlike the others, and someone who has only worked under CASS 7 will not recognise it.

CASS 7 — client money for investment business. The regime most people mean by “CASS”: investment firms, wealth managers, discretionary managers, platforms and brokers. It covers the client money rules proper — segregation, the internal and external reconciliations, the client money requirement and resource calculation, acknowledgement letters, and the client money and assets return. This is also where CASS 6 (custody assets) usually sits alongside, and firms rarely have one without the other.

CASS 15 — debt management client money. Applies to debt management firms handling money on behalf of customers in debt solutions. Smaller regime, distinct rules, and a materially different operational context — consumer-facing, high transaction volume, and with its own reconciliation and prudential expectations.

Alongside these, firms may encounter CASS 11 (debt management, historic), CASS 13 (claims management) and the safeguarding regimes for payments and e-money firms, which are not CASS at all but are frequently confused with it — covered in our guide to safeguarding for payments and e-money firms.

Why the experience is not transferable

Three reasons, and they compound.

The calculations genuinely differ. A CASS 7 client money requirement built from individual client balances is a different exercise from a CASS 5 calculation involving risk transfer and non-statutory trust. The underlying discipline — reconcile, evidence, resolve differences — transfers; the mechanics do not.

The failure modes differ. What goes wrong under CASS 7 tends to involve unallocated receipts, stale client balances and acknowledgement letters not in place. Under CASS 5 it more often involves risk transfer wrongly assumed, or premium and claims money commingled. An experienced person knows where to look in their own regime and does not in another.

The audit differs. The CASS audit is conducted against the applicable rules, and an auditor testing a CASS 5 position asks different questions from one testing CASS 7. Someone who has been through several audits in one regime has pattern recognition that does not carry across — see our guide to the CASS audit.

Qualification is the baseline — ICAEW, ACCA or CIMA — but it says nothing about regime experience. What does transfer is the mindset: the instinct that client money is not the firm’s money, the discipline of daily reconciliation, the willingness to escalate a breach rather than resolve it quietly. That is genuinely portable, and it is the thing worth valuing when the exact regime does not match.

Specifying the role properly

Four things to state, and the first two are where most specifications fail.

Name the regime. “CASS 7 and CASS 6 experience” is a filter; “CASS experience” is not. If you hold client money under CASS 5, say so — the broker and MGA market is a distinct talent pool and you will not reach it otherwise.

State what the role owns. Preparing the reconciliation, reviewing it, owning the calculation, owning the breach register, being the named contact for the CASS audit — these are different levels of responsibility and candidates read them carefully.

Say whether there is a CASS oversight function and whether this role is it. In smaller firms the finance person effectively is CASS oversight, which is a significantly different job carrying personal visibility to the regulator.

Describe the operational scale — number of client accounts, transaction volume, whether reconciliation is daily, and what systems support it. A candidate from a firm reconciling thousands of accounts daily has done something different from one at a small manager.

Our CASS accountant job description and salary guide provides a template covering these.

Testing for it at interview

Five questions that separate genuine ownership from adjacency, whichever regime applies.

1. Talk me through your reconciliation, step by step. The single most revealing question. Someone who has owned it describes the sources, the timing, the differences that recur and how they are cleared. Someone who has reviewed it describes the output.

2. Which regime, and what does your calculation actually involve? Ask them to explain the client money requirement or resource in their own words. This is where regime mismatch surfaces immediately.

3. Tell me about a breach. Everyone who has worked in client money has seen one. Strong answers describe identifying it, quantifying it, reporting it promptly and the remediation — not a claim that nothing has ever gone wrong.

4. What did your CASS auditor raise, and what changed? Ownership of findings rather than deflection, and the same question that works at every level of finance hiring.

5. Where would you look first in a firm you have just joined? Experienced people have a mental checklist: acknowledgement letters, unallocated receipts, stale balances, the age of differences. The answer reveals depth quickly.

Our CASS interview questions guide sets out the full sequence including breach scenarios.

When a different regime is acceptable

Being pragmatic matters, because the pool is small in every regime and tiny in some. A candidate from an adjacent regime is frequently the right hire where three things are true: they have genuinely owned a reconciliation and a calculation, not merely contributed; they have been through a CASS audit and can describe the findings; and there is someone in the firm — internal or external — who knows your regime and can support the transition. On that basis a strong CASS 7 candidate moving into a CASS 5 environment is a reasonable appointment with a three-month learning curve.

Where it is not acceptable: a firm with no existing CASS expertise appointing someone from a different regime as its sole client money resource. That combination puts an inexperienced-in-context person in a position of regulatory exposure with nobody to check against, and it is the situation where breaches most often go unnoticed.

What the market looks like

Three realities worth planning around. The pool is small and largely employed — CASS specialists rarely appear on job boards, so searches rely on direct approach. The premium is real: client money experience adds materially over equivalent commercial finance roles, and the FCA’s client assets pages set out the supervisory expectations that drive the demand, and CASS-specific roles price above general regulated finance. And the audit cycle drives timing — hiring in the run-up to a CASS audit is the hardest version of it, and an interim covering the period is frequently better than a rushed permanent appointment. Benchmarks are in our regulated-firm finance salary guide, and the CASS accountant recruitment practice covers the search.