Governance & MI Reporting
Control at the operational level. Confidence at the Board level.
CASS 15 does not just require firms to reconcile and safeguard, it requires firms to demonstrate that the right people know what is happening, at every level of the organisation.
Management information flows in three directions:
- Daily to operational teams resolving breaks and exceptions
- Regularly to management tracking deficits and regulatory risk
- Clearly to Boards overseeing the firm’s safeguarding position and any material incidents
For firms still relying on spreadsheets and manual reporting, producing timely, consistent MI remains an operational challenge.
Imperium(L) makes CASS 15 MI visible, evidenced and board-ready from a single operational control platform.
See how Imperium(L) surfaces the management information your firm needs across operational, management and Board tiers.
Imperium(L) Prism delivers MI through a structured three-tier system
Effective CASS 15 governance requires different MI at different levels. Imperium(L) is structured around all three.
1. Operational MI
Where the gap between policy and practice becomes visible. Prism gives teams full visibility across every metric that matters:
- Reconciliation volumes and timeliness
- Outstanding breaks
- Aged breaks
- Unallocated funds
- Rejected transactions
- Failed safeguarding transfers
- Missing data incidents
The result is a daily operational picture that is accurate, evidenced and ready for management review without anyone having to build it manually.
Outstanding breaks
Under CASS 15, every outstanding break is a potential indicator of client asset misallocation, data error or operational failure. Firms must identify, record and resolve breaks daily and evidence every step.
For firms still relying on spreadsheets or manual checks, breaks can sit unresolved for days without anyone knowing. By the time they are found, the escalation window has often already closed.
This is where Prism works
- Breaks are surfaced the same day they occur, not at month-end
- Every break is assigned an owner, severity level and resolution deadline automatically
- The full resolution trail is captured, timestamped and audit-ready without any manual assembly
- Resolution pack completeness is tracked in real time so firms can see exactly what is still outstanding
Unallocated funds
Every pound of relevant funds must be attributed to a specific client at a time. Unallocated funds that cannot be attributed create an immediate gap in the firm’s safeguarding position, one that can trigger a shortfall and a mandatory breach notification to the FCA.
For firms managing high transaction volumes across multiple accounts, unallocated balances can accumulate quickly and quietly, often going unnoticed until a reconciliation or audit surfaces them.
How Prism closes the gap
- Unallocated balances are flagged in real time as soon as they appear, not discovered retrospectively
- Automated allocation workflows reduce dwell time and minimise the risk of a reportable shortfall
- Every allocation action is logged with a full audit trail, giving the CASS oversight function complete visibility
- Management receives regular MI on unallocated fund volumes and resolution timescales as a standard output, not a manual exercise
2. Management MI
The difference between a firm that manages risk and one that discovers it too late is almost always visible in its management MI. Prism gives management teams a complete picture:
- Safeguarding deficits
- Root cause analysis trends
- Recurring break themes
- Regulatory incidents
- Exception volumes
- Outstanding remediation actions
Systemic weaknesses are identified early, remediation is tracked to closure and nothing is left unresolved when the auditor arrives.
Safeguarding deficits
A safeguarding deficit where the funds held fall short of what the firm owes clients is one of the most serious CASS events a firm can face. Firms must make good any shortfall from their own funds on the same business day it is identified. Delayed remediation is itself a breach.
For management teams without live visibility of their safeguarding position, a deficit can go undetected until a reconciliation is run. By then, the same-day remediation window may already have passed.
How Prism resolved this
- Live safeguarding positions are visible at all times, deficits are identified immediately, not at the next reconciliation cycle
- Same-day escalation alerts ensure management can act within the required timeframe
- Every deficit event is captured, root caused and tracked to closure within the CASS incident management framework
- When the auditor or regulator asks, the full deficit history and remediation trail is already there, timestamped, evidenced and ready to present
Regulatory incidents
Regulatory incidents such as reconciliation failures, segregation breaches, client money shortfalls must be captured, escalated, root caused and reported consistently, every time.
For management teams without a structured incident framework, incidents can be handled inconsistently, under-reported or poorly evidenced. That is exactly what an FCA supervision visit or CASS audit will expose.
With Prism in place
- Every incident is captured in a structured register with severity, root cause, remediation status and owner recorded as standard
- Trend analysis across incidents gives management early sight of systemic weaknesses before they escalate into enforcement action
- The CASS oversight function has a complete, current incident register at all times, no retrospective reconstruction before an audit
- Incident MI is surfaced to senior management regularly as a live output, not a manually assembled report
3. Board MI
Where safeguarding governance is either demonstrated or exposed, Prism consolidates the following into a single, Board‑ready view generated from controlled, evidenced data:
- Safeguarding health summary
- Material incidents
- Breach trends
- Reconciliation completion statistics
- Operational resilience incidents
The result is a Board that is informed, accountable, and impossible to catch off guard.
Safeguarding health summary
Under CASS 15, the Board carries ultimate responsibility for ensuring client assets are adequately protected That accountability requires a current, consolidated view of the firm’s safeguarding position.
For Boards relying on manually assembled packs, the health summary is often out of date by the time it is presented. Decisions are being made on stale data, and the evidence trail for regulators is incomplete.
The Prism difference
- A consolidated safeguarding health summary is available to the Board at any point, client money resource vs requirement, reconciliation status, outstanding breaks, open incidents and deficit positions in one view
- The summary is generated from controlled, evidenced reconciliation data, not assembled manually
- Board members have the evidence trail they need to demonstrate active oversight under SMCR, without relying on the operations team to build it
- A deteriorating health position triggers early warning alerts, giving the Board time to intervene before a situation becomes a regulatory event
Material incidents
Under CASS 15 and SMCR, material incidents must reach the Board without delay with root cause, impact and remediation documented. The FCA expects evidence that the Board was informed and acted on it.
For firms without a structured escalation framework, material incidents get resolved at operational level and never reach the Board. When the FCA asks for evidence of Board oversight, there was none.
How Prism removes the risk
- Material incidents are automatically escalated to named Senior Managers as soon as they are identified and nothing stays at operational level by default
- Every incident arrives at Board level with root cause analysis, impact assessment and a documented remediation plan already attached
- The full escalation trail; who was notified, when, what action was taken and when it was resolved is captured and audit-ready
- Recurring incidents in the same category trigger pattern alerts, giving Boards early sight of control failures before the regulator does
More than a reporting layer
MI is the visible output of good operational control. Prism does not just surface the numbers, it generates them from a controlled, evidenced process.
Before
- Manual Reconciliation
- Spreadsheet Evidence
- Period-end Checks
- Hidden Discrepancies
- Disconnected Reports
- Reactive Issue Management
- Fragmented Data
With Prism
- Controlled Workflows
- Structured Audit Trails
- Ongoing Visibility
- Clear Exception Handling
- Embedded Dashboards
- Early Intervention
- Single Operational Overview
Book a demo
Demonstrate CASS 15 control at every level. See how Imperium(L) uses Prism to build the MI framework to support your operational, management and Board reporting.
Frequently asked questions
What does CASS 15 require from firms in terms of management information?
CASS 15 requires firms not only to safeguard and reconcile client money but to demonstrate that the right people know what is happening at all times. It expects structured management information that flows daily to operations, regularly to management, and clearly to Boards, evidencing control and oversight at every level.
How does Prism support operational management information (MI)?
At the operational tier, Imperium (L) surfaces metrics such as outstanding breaks and unallocated funds in real time. Breaks are detected the same day they occur, assigned ownership and resolution deadlines automatically, and logged with full audit trails. Unallocated funds are flagged instantly and resolved through automated workflows, producing ongoing visibility and standardised MI.
What type of management‑level MI does Prism provide?
Management MI in Imperium (L) enables senior managers and compliance officers to oversee systemic risk, safeguarding deficits, and regulatory incidents. Live safeguarding positions identify deficits immediately for same‑day remediation, while regulatory incidents are captured, root‑caused, and analysed in a structured register, giving management consistent, audit‑ready evidence of governance.
How does Prism help Boards meet their CASS 15 and SMCR obligations?
Imperium (L) provides Boards with a live safeguarding health summary and direct visibility of any material incidents. The Board can see client‑money resources, reconciliation status, incidents, and deficits in one evidenced view, supported by automatic escalation of material incidents to Senior Managers and full documentation of every action taken for FCA and audit review.