Wind‑Down Planning

Operational readiness for an orderly, FCA‑compliant exit

Imperium (L) brings every safeguarding, liquidity, and dependency control together in one automated Wind‑Down Pack framework — designed to evidence full returnability, liquidity coverage, and operational continuity on Day 1.
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How Imperium(L) Prism supports wind-down planning

Wind-Down Data Pack

CASS 15.11 — Customer returnability assessment & shortfall attribution

On wind-down activation, firms must produce a complete, point-in-time picture of every customer’s entitlement. The Data Pack automatically classifies each client in the safeguarding ledger by return complexity and attributes any existing reconciliation breaks to the responsible account — producing a hash-stamped JSON snapshot that serves as the insolvency practitioner’s Day 1 data set.

Imperium (L) Wind‑Down Data Pack dashboard presenting customer returnability assessment and shortfall attribution under FCA CASS 15, showing total liabilities, uncovered exposures, client coverage categories (green, amber, red), and detailed shortfall attribution by customer and account.
Key Capabilities
  • Green / amber / red returnability classification per client, based on reconciliation status and data completeness
  • Shortfall attribution by type — coverage shortfall (pro-rata gap) or value break (reconciliation discrepancy)
  • Multi-currency liability aggregation across all active safeguarding accounts
  • One-click JSON export with cryptographic hash stamp for audit integrity
Outputs Delivered
  • Hash-stamped JSON snapshot
  • Shortfall attribution table
  • Coverage % per client
  • Returnability summary
Regulatory basis:

CASS 15.11 requires firms to maintain a wind-down data pack that can be produced immediately on activation, evidencing each customer’s entitlement and any reconciliation shortfall.

Imperium (L) Wind‑Down Planning — Cost & Liquidity Model dashboard displaying total wind‑down costs, daily burn rate, cash runway, and headroom, with detailed cost breakdowns and month‑by‑month projections for firms under FCA CASS 15 regulations.

Cost & Liquidity Model

PS25/12 §4.11–4.12 — Financial monitoring & adequate financial resources

Projects month-by-month cash consumption across the entire closure window, splitting costs into continuing, reducing, and extraordinary buckets. Firms can toggle between a base and stressed scenario to stress-test runway assumptions and immediately see whether the FCA’s Month-1 cost-reduction benchmark is met.

Imperium (L) Wind‑Down Planning — Cost & Liquidity Model dashboard displaying total wind‑down costs, daily burn rate, cash runway, and headroom, with detailed cost breakdowns and month‑by‑month projections for firms under FCA CASS 15 regulations.
Key Capabilities
  • Configurable closure window (in months) with one-click toggle between base and stressed scenario
  • Daily burn rate and total wind-down cost surfaced as headline KPIs
  • Month-by-month breakdown of continuing, reducing, and extraordinary costs with cash remaining
  • FCA benchmark alert triggered when projected Month-1 cost reduction falls below 50%
  • Headroom calculation showing surplus after full wind-down against starting cash position
Outputs Delivered
  • Printable cost model
  • Month-by-month projection table
  • Base & stressed scenarios
  • FCA benchmark indicator
FCA benchmark

Month-1 cost reduction rarely falls below 50% in payment institution wind-downs. Where projected costs remain above this threshold, the firm should review its redundancy and contract termination strategy. Source: FCA Wind-Down Planning Review, June 2025.

Triggers & Management Information

PS25/12 §4.11 & §5.9 — Financial monitoring & operational resilience

A real-time trigger framework that monitors six risk families — liquidity, runway, safeguarding, capital, vendor, and revenue — across three escalation tiers: early warning, escalation, and activation. Each trigger maps to a named PS25/12 or CASS obligation, giving firms a clear regulatory hook for every breach logged and a defensible audit trail.

Imperium (L) Wind‑Down Planning Triggers and Management Information dashboard displaying early‑warning, escalation, and activation breaches with live financial and operational trigger metrics, covering liquidity, safeguarding, vendor, capital, and cyber event monitoring under FCA CASS 15 requirements.
Key Capabilities
  • Three-tier escalation structure: Early Warning → Escalation → Activation, with independent breach counts per tier
  • Six risk families monitored: Liquidity, Runway, Safeguarding, Capital, Vendor, and Revenue
  • Each trigger tagged to a specific PS25/12 or CASS rule reference for immediate regulatory traceability
  • Live current value vs. threshold comparison with colour-coded breach status per trigger
  • Audit log persistence enabling firms to evidence the breach timeline and management response to regulators
Outputs Delivered
  • Real-time trigger dashboard
  • Breach status per trigger
  • Regulatory rule reference mapping
  • Audit log export
FCA finding (June 2025):

Most firms lacked a clearly defined safeguarding trigger — specifically one tied to D+1 shortfall duration and magnitude. Triggers T07 and T08 directly address this gap.

Imperium (L) Wind‑Down Planning — Cost & Liquidity Model dashboard displaying total wind‑down costs, daily burn rate, cash runway, and headroom, with detailed cost breakdowns and month‑by‑month projections for firms under FCA CASS 15 regulations.

Critical Vendor Dependency Map

PS25/12 §5.9 — Evidencing orderly exit from material third-party dependencies

A live vendor register that captures every material third-party relationship a firm relies on to operate and wind down. Each vendor is rated by criticality, category, notice period, termination fee, exit clause status, data SLA, and replacement lead time — with a Gap Report isolating vendors that represent a wind-down stopper due to missing exit documentation.

Imperium (L) Wind‑Down Planning — Cost & Liquidity Model dashboard displaying total wind‑down costs, daily burn rate, cash runway, and headroom, with detailed cost breakdowns and month‑by‑month projections for firms under FCA CASS 15 regulations.
Key Capabilities
  • Vendor register filterable by criticality (critical / important / replaceable)...
  • ...and by category (safeguarding bank, PSP, processor, cloud, KYC/AML, legal, outsourced ops, group treasury)
  • Exit clause status flagged as Documented or GAP — critical vendors with a GAP are flagged as wind-down stoppers
  • Contracts maturing within the defined closure window highlighted automatically
  • Named owner per vendor row for clear accountability and escalation routing
  • Gap Report view isolating all undocumented exit clauses for immediate remediation
Outputs Delivered
  • Full vendor register
  • Gap report
  • Maturing contracts alert
  • Owner accountability log
Regulatory basis:

PS25/12 §5.9 requires firms to evidence an orderly exit from all material third-party dependencies. Vendors flagged as critical with no documented exit clause represent a potential wind-down blocker.

Customer Fund Return Runbook

CASS 15 — Print-ready wind-down execution pack

Ties all upstream modules into a single, print-ready execution pack that an insolvency practitioner or CASS Officer can act from on Day 1. The runbook sequences customer fund returns by classification, maps critical vendor pre-conditions, surfaces pre-populated regulatory communication templates, enforces a three-tier sign-off, and presents the full customer coverage position — all in one document.

Outputs Delivered
  • Downloadable CSV (all sections)
  • Regenerate on demand
  • Print-ready layout
  • FCA letter template
  • Customer notification template

1. Customer Return Sequencing

Customers ordered green → amber → red, with return channel (automated BACS/SWIFT or manual review) and account reference per client

Imperium (L) Wind‑Down Planning dashboard displaying the Customer Fund Return Runbook, showing total liabilities, active safeguarding accounts, and customer return sequencing classified by returnability (green, amber, red) with automated and manual return channels under FCA CASS 15 execution.

2. Critical Vendor Dependencies for Fund Return

Vendor pre-conditions mapped with exit clause status and data return SLA, flagging any GAPs that must be resolved before return commences

3. Communication Templates

Pre-populated FCA regulatory letter and customer notification templates with bracketed placeholders ready for completion

Imperium (L) Wind‑Down Planning dashboard displaying critical vendor dependencies for fund return under FCA CASS 15, including notice periods, exit clauses, and data return SLAs, alongside standardized regulatory communication templates for the FCA and client notifications.

4. Sign-Off Block

Three-tier authorisation required before fund return commences: Reconciliation Analyst (Tier 1) → Head of Operations (Tier 2) → Head of Compliance / CASS Officer (Tier 3)

5. Customer Coverage Position

Full pro-rata share table per client showing balance, amount covered, shortfall, coverage %, and account reference

Imperium (L) Wind‑Down Planning interface showing sign‑off block for multi‑tier authorisation before customer fund return, and customer coverage position dashboard displaying client balances, covered amounts, shortfalls, and percentage coverage under FCA CASS 15 requirements.

Be wind‑down ready from day one

Demonstrate full CASS 15 and PS25/12 compliance with an automated framework that unites customer data, liquidity, triggers, vendors, and fund‑return execution in one FCA‑ready platform.
Imperium (L) Prism instantly gives you the evidence your regulator expects.

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Frequently asked questions

What is wind‑down planning under CASS 15 and PS25/12?

Wind‑down planning requires firms to demonstrate that they can exit the market in an orderly, compliant manner. Under CASS 15 and PS25/12, firms must evidence how customer funds would be returned, how ongoing costs would be met, and how critical third‑party dependencies would be managed. Prism structures this through five modules that cover data, costs, triggers, vendors, and fund‑return execution.

A firm must produce a complete, point‑in‑time picture of every customer’s safeguarded entitlement, the associated shortfalls, and the full operational plan for returning those funds. This includes detailed liquidity projections, vendor dependencies, and a print‑ready runbook for insolvency practitioners or CASS Officers to act from on Day 1.

 

Wind‑down frameworks require continual monitoring of key financial metrics and triggers — such as liquidity, runway, and safeguarding positions — to confirm that adequate resources remain throughout the closure window. Benchmarking against FCA standards, like the Month‑1 cost‑reduction threshold of 50%, provides measurable assurance that a firm’s plan remains viable under both base and stressed scenarios.

Regulations require firms to evidence an orderly exit from all material third‑party dependencies and to demonstrate capability to notify customers and regulators promptly. Mapping vendor exit clauses, data SLAs, and replacement times — alongside ready‑to‑issue communication templates and a structured sign‑off process — ensures the firm can execute returns and notifications without delay or compliance risk.

Core outputs include a hash‑stamped customer data snapshot, shortfall attribution tables, month‑by‑month cost projections, vendor gap reports, regulatory trigger dashboards, and a print‑ready runbook combining all workflow stages. Together these artefacts provide the evidence the FCA expects under CASS 15 and PS25/12 to show that a firm can wind down safely and protect customer funds.

 

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