7 March 2018
AVP, HSS CASS Assurance
GROUP Job Code
Global Career Band
Job Sub Family
Job Purpose (overall high level summary of the role)
This position is pivotal to ensuring the organisation maintains strong standards and the highest levels of compliance as they relate to the Financial Conduct Authority's (FCA) UK CASS (client assets protection) regime.
Post the insolvency of Lehmans Brother International (Europe), the FCA continues to focus on the protection of client assets. The FCA CASS Unit carries out specialist and intensive supervision of client assets with the aim of ensuring that firms have robust systems in place to assist in the prompt return of client assets due to a firm's insolvency. Punitive fines has been imposed on organisations for failure to uphold the appropriate levels of protection.
HSBC Bank plc (HBEU) is a custodian of client assets and does not hold client money (as defined in the CASS rules). HSBC Securities Services (HSS) accounts for 99% of the USD2 trillion of client assets serviced by HBEU. HSS has businesses in the UK, Greece and Luxembourg that fall within the scope of CASS.
The role holder will form part of a dedicated team and drive increased levels of CASS assurance through, and not limited to, robust governance, incident investigation and read-across, employee education and training, Client Money and Assets Reporting (CMAR) due diligence, deep dive reviews and assurance testing.
The role is sccountable to the Senior Manager CASS Assurance City Offices who reports to to the Global Head of HSS CASS Assurance. The Global Head of HSS CASS Assurance reports to the Chief Operating Officer, HSS, Europe.
Principal Accountabilities: key activities and decision making areas
Typical Targets and Measures
Impact on the Business/Function
- Implement strategy to enhance client assets protection within the business
- Maintain a robust CASS governance framework with supporting MI
- Promptly assess and clearly communicate risks to the Senior Manager CASS Assurance City Offices, Global Head of HSS CASS Assurance or COO. Propose solutions and oversee the effective execution of mitigation plans
- Institutionalize a robust training programme to increase CASS awareness and understanding
- Provide leadership and direction on incident reviews (breaches). Ensure that appropriate read-across is undertaken and drive robust remediation to timely completion
- Act as a point of coordination for external/internal audits and reviews. Ensure any points are completed by target date or escalated on a timely basis
- Define and execute against an end to end assurance and testing plan, thereby reducing the risk of unidentified or long standing control lapses
- Support guiding the global HSS business on conformance with HSBC's Client Asset Policy and the sharing of best practices to continuously improve the control and protection of client assets.
Evidence from agenda/minutes demonstrating strong governance structure, challenge & decision making
Accurate, consistent and timely production of MI
Escalation of incidents within policy timeframes
Annual training plan with % completion and evaluation metrics
Year on year reduction in number of incidents raised
Completion of audits/reviews within prescribed timeframes
Completion of quarterly testing programme
Audit/review findings, stakeholder feedback and tested understanding of policy
Customers / Stakeholders
- Develop and maintain strong relationships with the management teams across HSS Europe, our intra-group service providers and other key stakeholders
- Support the COO and Client Assets Oversight Officer office in executing their responsibilities as they relate to HSS
- Demonstrate effective partnership with Internal and External Audit, Compliance and BRCM teams
- Provide succinct communication of progress, risks and issues to senior management
Evidence within the organisation of prompt convergence and agreement on points of rule interpretation
Completion of audits/reviews within prescribed timeframes
Feedback on timely raising, interpretation and problem solving relating to key risks
Leadership & Teamwork
- The role requires proactive collaboration with multiple stakeholders at different levels of seniority in order to successfully deliver results
- Use effective influencing skills to ensure delivery of business objectives and increase CASS knowledge and capability across the business
- Support achievement of the HSBC vision, values, goals and culture in personal behaviour, actions and decision making
- Provide technical leadership and support technical excellence by searching out external best practice, monitoring technical and professional developments, sharing knowledge and encouraging others to do the same
Evidence of an active role within the HSS service center management team (360 degree feedback)
Increase in % pass rate on training modules
360 degree feedback
Attendance at industry and working group forums
Operational Effectiveness & Control:
- Assess the resiliency of the HSS's control framework in the context of CASS, escalating areas of concern on a timely basis and supporting management in the implementation of effective solutions
- Lead the development, implementation and maintenance of CASS management information and analysis. Ensure the reporting framework supports and informs on a timely basis and leads to effective risk assessment and resolution
- Support the Senior Manager CASS Assurance City Offices and Global Head of HSS CASS Assurance in executing a robust CASS governance framework. Drive procedures, practices and standards to ensure quality, effective risk management and regulatory compliance
- Demonstrate that controls are in place to meet criteria required for CASS Resolution Planning
- Implement risk based testing (assurance) approach to assess end to end operating effectiveness of CASS processes and controls
Maintain a golden source set of CASS process maps and control points
Documented CASS governance agenda, minutes and points of escalation/communication to CASS Executive Group
Demonstrable improvement in CASS risk profile over course of year
Successful tests of CASS Resolution Plan
Execution of test plan & year on year increase in success rates
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Management of Risk (Operational Risk / FIM requirements)
- The jobholder will ensure the fair treatment of our customers is at the heart of everything we do, both personally and as an organisation. This will be achieved by consistently displaying the behaviours that form part of the HSBC Values and culture and adhering to HSBC risk policies and procedures, including notification and escalation of any concerns and taking required action in relation to points raised by audit and/or external regulators
- The jobholder will continuously reassess risks associated with the role and inherent in the business, taking account of changing economic or market conditions, legal and regulatory requirements, operating procedures and practices, management restructurings, and the impact of new technology.
- Ensure all actions take account of the likelihood of operational risk occurring, addressing areas of concern in conjunction with Risk and relevant line colleagues, and also by ensuring that actions resulting from points raised by internal or external audits, and external regulators, are correctly implemented in a timely fashion.
Observation of Internal Controls (Compliance Policy / FIM requirements)
- The jobholder will adhere to, and be able to demonstrate adherence to, internal controls and will implement the Group compliance policy by adhering to all relevant processes/procedures. The term 'compliance' embraces all relevant financial services laws, rules and codes with which the business has to comply. This will be achieved by adherence to all relevant procedures, keeping appropriate records and, where appropriate, by the timely implementation of internal and external audit points, including issues raised by external regulators
- The jobholder will implement measures to contain compliance risk across the business area. This will be achieved by liaising with Compliance department about business initiatives at the earliest opportunity. Also and when applicable, by ensuring adequate resources are in place and training is provided, fostering a compliance culture and optimising relations with regulators.