I don’t think you should do that…
I’m unclear what it is that Andrew and I have in our DNA that makes us want to do tricky stuff – some weird point to prove, extreme stubbornness, not sure. In many respects Andrew and I couldn’t be more different. Andrew is always crying in meetings and I’m more on a level keel not giving too much away – 😉 . However we both have some crazy desire to prove “them” wrong, whoever “they” are!
Anyway, so started the latest chapter in the ShareIn story. We needed a solution to hold Client Money (not e-money, real money). We searched high and low and couldn’t find an API driven Client Money solution. Nowhere, I mean it wasn’t that we found something and it was too expensive or something, it didn’t exist. So what else to do but do it ourselves obviously?!
There were two very large parts to this puzzle – the Regulations and the Technology.
ShareIn needed to obtain the regulatory permissions from the Financial Conduct Authority. To say this is difficult is a little bit of an understatement. There are few things in the Financial Regulatory environment more important than holding other people’s money.
Variation of Permissions – ShareIn had to apply to the FCA to allow us to hold Client Money. ShareIn would have a duty to protect the customer money we hold, make adequate arrangements to safeguard clients’ rights, and to prevent use of these funds for ShareIn’s own account. There is very detailed guidance from the FCA on this called CASS (Client Assets Sourcebook) and in particular Chapter 7 explains the CASS Money Rules.
CASS Exams* – I sat some exams to learn about the regulations and to enable me to become a CF10a. I’m an ICAEW Chartered Accountant and it had been 16 years since the last exam I sat (Association of Corporate Treasury) so I had a fun! I had to learn the very detailed regulations. CISI do an excellent course/handbook/exam. They recommend spending 80 hours studying, although I only really had time to spend about 50 hours.
We obtained the new permissions on the 15th April 2019 and my CF10a in May 2019.
We’ve updated and included a new chapter of our online Compliance Manual titled Client money reconciliation and reporting (CASS), which includes our internal client money procedures and how we carry out reconciliations.
A compliant payments tool
I think I should leave it to Andrew to explain more about the technical development but what the team have achieved in such a small space of time has been phenomenal. I’m incredibly proud of what has been accomplished by the amazing team who’ve worked so hard on this. I’m pretty sure any of the Developers and our brilliant Designer could walk into a job working in CASS Compliance now!
But this has been very much a team effort. Without the rest of the ShareIn team keeping our existing products maintained and our clients serviced this wouldn’t have been possible.
This is just the start of ShareInPay and we’re very excited to tell you more soon.
If you’re interested in ShareIn for your investment activity, then please get in touch.
*The list of exams is contained here TC App 4.1.1C. You need to check exams that satisfy the requirement for activity 16, which includes holding client money. Exams with a 1; with a 2 and 3; or with a 4, 5 and 6, will meet the requirement.