A CASS resolution pack is designed for the point at which a payment or electronic money institution may no longer be able to explain its safeguarding arrangements itself.
That is why the FCA requires the information to exist before a failure occurs.
For safeguarding institutions receiving or holding relevant funds under CASS 15, CASS 10A requires a resolution pack containing the records and documents needed to understand the safeguarding structure, identify relevant funds and support their timely return.
The pack must be maintained on an ongoing basis and relevant documents must be capable of retrieval as soon as practicable and, in any event, within 48 hours in the circumstances specified by the rules.
This makes the resolution pack one of the most practical tests of whether a firm's CASS 15 framework is genuinely under control.
What is a CASS 15 resolution pack?
The formal rules sit in CASS 10A, although the pack is directly connected to CASS 15.
CASS 10A applies to a safeguarding institution when it receives or holds relevant funds in accordance with CASS 15.
Its purpose is to ensure that information is available to support the return of relevant funds if the institution becomes insolvent and to assist relevant authorities in a resolution or failure scenario.
In practical terms, an insolvency practitioner should not need to spend weeks discovering where customer money is held, who controls it, which agreements apply or how the firm's safeguarding records work.
The resolution pack is intended to provide that map.
Does the resolution pack need to exist at all times?
Yes.
CASS 10A requires the safeguarding institution to maintain and be able to retrieve its resolution pack.
The FCA's guidance makes clear that the documents should already exist and be maintained rather than using the retrieval window to start producing them after a request.
This distinction is critical.
A folder called "resolution pack" containing last quarter's documents is not enough if the underlying arrangements have changed.
The pack needs to reflect the firm's current safeguarding structure.
What is the 48-hour resolution pack rule?
The institution must have adequate arrangements enabling specified insolvency office holders to retrieve each required document as soon as practicable and in any event within 48 hours of appointment.
The institution must also be able to retrieve each document within that period where it decides to do so or receives an FCA or Bank of England request.
Certain records should be retrievable immediately.
These include specified institutional information, acknowledgement letters, insurance or guarantee information, information identifying key individuals and the most recent internal and external safeguarding reconciliation records.
The 48-hour requirement should therefore be treated as a maximum backstop, not as a target for every document.
What must a CASS resolution pack contain?
The detailed requirements are contained in CASS 10A.2 and CASS 10A.3.
The core contents include a master document containing enough information to retrieve the other documents in the pack.
The pack must identify institutions appointed for receipt or holding of relevant funds and, where applicable, relevant assets.
It must contain relevant executed agreements, side letters and acknowledgement letters relating to those arrangements.
Where insurance or a guarantee is used, the pack needs the required information and relevant policy or guarantee documentation.
It must identify relevant agents and electronic money distributors.
It must also record relevant group members and third parties involved in operational safeguarding functions, including information necessary to understand access and control arrangements.
The firm's procedures for management, recording and transfer of relevant funds and relevant assets form part of the pack.
Key senior managers, directors and other individuals important to safeguarding operations must also be identifiable, including the individual with CASS 15 operational oversight responsibility.
Specified CASS 15 records, safeguarding policies and procedures and standard client terms must also be included as applicable.
Why reconciliation records matter to the resolution pack
A resolution pack is not merely a collection of contracts and policies.
The latest reconciliation evidence is particularly important because it helps demonstrate the current safeguarding position.
CASS 10A therefore connects directly with CASS 15.8.
The firm should be able to produce its most recent required internal and external safeguarding reconciliation records together with the wider records necessary to understand the position.
If those records are spread across spreadsheets, shared drives, email chains and individual employees' files, achieving immediate or 48-hour retrieval can become unnecessarily difficult.
This is one area where operational CASS 15 technology can materially strengthen resilience.
How current must the resolution pack be?
CASS 10A requires ongoing review of the pack.
Where a change in circumstances makes the content of a specified document materially inaccurate, the inaccuracy must be corrected promptly and, in any event, no more than five business days after the change arises.
This is a much higher standard than an annual review.
Changes that may affect the pack can occur regularly.
A safeguarding bank may change.
An account may open or close.
A third-party provider may be replaced.
An agent may be appointed.
A senior manager may leave.
Policies may be amended.
Account details or agreements may change.
The resolution-pack process therefore needs a trigger mechanism through which operational changes reach the person or system responsible for maintaining the pack.
Can the CASS resolution pack be electronic?
Yes.
CASS 10A permits documents to be held electronically provided that the institution can continue to satisfy the retrieval and accuracy requirements.
For most modern firms, electronic maintenance is likely to be operationally preferable.
The important issue is not whether the document is electronic.
It is whether authorised people can actually find and retrieve it during a stressed situation, including after insolvency where access to normal systems or individuals may be disrupted.
Firms relying on technology should therefore consider continuity of access as part of the resolution design.
Why manually maintained resolution packs fail
The main weakness of a manually assembled pack is drift.
The pack is accurate on the day somebody completes it.
The operating business then continues changing.
A new bank account is opened, a policy is amended or a provider changes, but the resolution folder is not updated because the operational change and the compliance document are managed separately.
Months later, the pack still looks complete while containing information that is no longer correct.
This is why CASS 10A requires ongoing maintenance rather than periodic reconstruction.
Using Safeheld for CASS 15 resolution-pack readiness
Safeheld connects operational safeguarding information with reconciliation, regulatory reporting, audit evidence and resolution-pack records.
For a firm using technology in this way, the objective is not to press a button after an FCA request and create a pack from scratch.
The objective is to maintain the underlying evidence continuously so that the required resolution information remains available and current.
This is particularly valuable for records that change frequently, such as reconciliation evidence and operational safeguarding information.
Static legal documents still need appropriate document control, but linking them to the same compliance environment can reduce the risk that operational and documentary records become inconsistent.
What should the board receive?
CASS 10A requires the governing body to receive a report concerning compliance with the resolution-pack rules at least annually.
A meaningful report should go beyond confirming that a folder exists.
Management should consider whether the pack is complete, whether material changes were incorporated within the required timeframe, whether immediate-retrieval information can actually be obtained immediately and whether a full retrieval test can be completed within 48 hours.
A practical dry run is usually more informative than reviewing a checklist alone.
The test should assume that the people who normally maintain the pack are not all available.
That is closer to the scenario for which the rules exist.
When should firms seek specialist advice?
A resolution pack depends on the quality of the safeguarding framework beneath it.
If the firm's safeguarding accounts, reconciliation methodology, contractual arrangements, policies or third-party structure are unclear, simply creating more documents will not solve the underlying issue.
Buckingham Capital Consulting provides specialist safeguarding and CASS 15 advisory support, including resolution-pack reviews, safeguarding policies, reconciliation methodology, audit readiness and remediation.
A specialist regulatory review can be particularly useful where a firm is unsure whether its current pack reflects the actual business or where an audit or FCA review has identified weaknesses.
CASS 15 resolution pack checklist
A firm reviewing its pack should test at least the following:
- Is there a current master document?
- Are all safeguarding institutions and relevant accounts correctly identified?
- Are executed agreements and relevant side letters available?
- Are required acknowledgement letters current?
- Are insurance or guarantee documents included where applicable?
- Are agents and distributors correctly recorded?
- Are relevant group entities and third parties identified?
- Can required information held by third parties be accessed?
- Are safeguarding procedures current?
- Are key safeguarding personnel and responsibilities current?
- Are required CASS 15 records included?
- Are safeguarding policies and standard client terms included where required?
- Is the most recent reconciliation evidence immediately retrievable where required?
- Are material changes reflected within the applicable timeframe?
- Can the complete pack be retrieved within 48 hours without relying on one individual?
The final question is often the most revealing.
A resolution pack is useful only if it remains usable when the firm is under severe operational stress.
Frequently Asked Questions
It is the resolution pack required under CASS 10A for safeguarding institutions receiving or holding relevant funds under CASS 15. It contains documents and records intended to support the identification and timely return of safeguarded funds if the institution fails.
The required documents must be retrievable as soon as practicable and in any event within 48 hours in the circumstances specified by CASS 10A. Certain important records should be immediately retrievable.
It must be reviewed on an ongoing basis. A material inaccuracy caused by a change in circumstances must be corrected promptly and in any event within five business days of the change arising.
Yes, provided the institution can continue meeting the FCA's retrieval and ongoing accuracy requirements.
Yes. Technology such as Safeheld can connect current safeguarding data, reconciliation evidence, reporting and resolution records, reducing reliance on manually maintained snapshots. The regulated institution remains responsible for the completeness and accuracy of the pack.