The FCA’s focus on CASS 15 has made it clear that firms holding client assets must demonstrate a higher level of readiness and ongoing oversight. The regulator’s priorities are centred on ensuring firms can evidence robust controls, accurate record-keeping, and the ability to respond quickly to any issues that put client money at risk. For smaller and mid-sized firms, this raises the question of whether the current compliance set-up can deliver against these expectations without undue pressure on other parts of the business.

This is not legal advice. It is market guidance based on what we see when working with clients who are preparing for regulatory change or responding to FCA findings. Firms should always seek specialist compliance and legal advice when implementing or adjusting their CASS framework.

In our experience, many firms still rely on a single Head of Compliance to oversee CASS responsibilities alongside a full range of other duties. While this can work in steady conditions, regulatory intensification often stretches that individual to the point where other priorities begin to slip. CASS obligations are time-sensitive and detail-driven. They require consistent monitoring and the ability to identify and address potential breaches before they escalate. When this responsibility sits on top of an already full workload, even the most capable professionals can find it difficult to give the required attention to the finer points of client asset regulation.

This is where resourcing decisions become critical. Some firms decide to hire a CASS compliance officer on a permanent basis, creating dedicated capacity for the oversight of client asset rules. This can make sense where CASS obligations are complex or central to the business model, and where the firm expects the workload to remain high. Others bring in fixed-term or contract compliance specialists who can focus exclusively on CASS readiness in the run-up to a review or thematic visit. This approach can be more cost-effective if the need is driven by a specific event, such as a system change or FCA engagement, but it also depends on having strong continuity plans once the contract ends.

The decision between in-house and contract support often comes down to whether CASS is a core, ongoing regulatory risk for the business or a significant but temporary focus. Permanent hires bring embedded knowledge and a long-term view, while contractors offer concentrated expertise and can hit the ground running. Both require careful selection, cultural fit, and clear definition of responsibilities to ensure the Head of Compliance can operate at a strategic level without losing sight of operational accuracy.

The market for professionals with deep CASS experience is competitive. The best candidates are often in roles where they are already adding measurable value to oversight and reporting processes. Hiring successfully in this space requires a clear brief and a willingness to move quickly when the right person becomes available. At Fram Search, we have worked with firms across the buy-side to hire CASS compliance officers, contract specialists, and broader compliance resource to strengthen client asset governance. We understand the trade-offs between speed, cost, and cultural fit, and how to present opportunities in a way that engages passive talent.

CASS 15 is not simply a regulatory box to tick. It is a framework designed to protect client assets and preserve trust in the financial system. Firms that invest in the right compliance resource, whether permanent or temporary, reduce operational risk and create space for senior leaders to focus on growth and strategy. With the FCA signalling that client asset oversight remains a high priority, now is the time to ensure your compliance structure is robust enough to meet the standard. If you are looking to hire a CASS compliance officer or review your CASS 15 compliance resource, we would be pleased to discuss how to identify and secure the talent you need.