Safeguarding. Checked every business day.
CASS 15 safeguarding software that does the daily work. Each legal entity's own rule applied to its own figures every business day: what it owes customers, which funds count, every shortfall found and fixed under approval, and the return its regulator expects.
Each company, against its own rule and deadline.
Every licence, its own rules.
Each set of rules is drafted from the law, approved by a named Safeheld reviewer and dated. Every result keeps the version it was checked against.
United Kingdom
- E-money, segregation
- E-money, insurance or guarantee
- Payment services, CASS 15
European Union
- Netherlands, Wft 3:29a
- Netherlands, Bpr 40a and 40b
- Lithuania, payment services
- Lithuania, e-money
- Ireland, payment services
- Ireland, e-money
United States
- California
- Texas
- New York
- Florida
- Washington
- Stablecoin reserves
Canada, Australia, Singapore, Hong Kong
- RPAA end-user funds
- Client money, s.981B
- E-money float
- Relevant money
- Stored value float
Balanced is not safeguarded.
A reconciliation can balance to the penny and still leave customers exposed. Among UK payment and e-money firms that failed between 2018 and mid-2023, the average shortfall was 65% of the money owed to customers. FCA, CP24/20, paragraph 1.3.
Each company's money against its own customers.
Positions per entity, never offset across the group.Only accounts and assets that count under that entity's rule.
Acknowledgement letters, account forms, policy cover and expiry checked.The check at each regulator's deadline, in its time zone.
Deadline and time zone set per entity and rule.What is owed, measured the way that licence measures it.
Customer-level balances, outstanding obligations or average daily liability, as the rule says.The safeguarding day.
Reconcile, resolve, forecast, approve and report, every business day.
01Reconcile
Internal and external reconciliations for each entity, pool and currency, from statements received by secure file transfer or upload.
02Resolve
Differences worked to their cause. Breaches entered in the register with materiality, deadline and, in the UK, the notification letter.
03Forecast
Funding needs for each entity over 24 hours, 7 days and 30 days, before a shortfall can form.
04Approve
Top-ups and excess withdrawals proposed with the regulator's deadline, approved by up to three people with two-step verification.
05Report
The FCA return ready to file; NMLS, Bank of Canada, DNB, MAS, ASIC, HKMA and GENIUS Act reports prepared in each regulator's structure; locked records anyone can verify.
What each regulator receives.
| Regulator | What the rule tests | What Safeheld produces |
|---|---|---|
| Financial Conduct AuthorityUnited Kingdom | CASS 15 and the Electronic Money Regulations. | Monthly safeguarding return, ready to file in My FCA. Resolution pack and annual audit pack. |
| State regulators through NMLSUnited States | State permissible investments. | MSB call report as a CSV in the NMLS upload layout. |
| Payment stablecoin regulatorUnited States | GENIUS Act reserves. | Monthly reserve composition report with CEO and CFO certification. |
| Bank of CanadaCanada | Retail Payment Activities Act, section 20. | Annual report sections 2 and 4 for PSP Connect. |
| De Nederlandsche BankNetherlands | Wft 3:29a, Bpr 40a and 40b. | T80.01 and T83.00 workbook for DLR. |
| Monetary Authority of SingaporeSingapore | Payment Services Act 2019, section 23. | PSN04 Form 8 and Form 5 in the MASNET layout. |
| Australian Securities and Investments CommissionAustralia | Corporations Act, section 981B. | FS71 Part 2 with the client money schedule. |
| Hong Kong Monetary AuthorityHong Kong | Stored Value Facilities Ordinance. | SVF review pack on the HKMA template you upload. |
Every report is reviewed and approved by your team before it is filed.
Questions.
Does the FCA require CASS 15 software?
No. The FCA requires the outcome: reconciliations every reconciliation day, accurate records, the monthly safeguarding return, a resolution pack retrievable within 48 hours and, for most firms, an annual safeguarding audit. Software is how most firms meet those duties without adding staff.
Will software make us compliant on its own?
No. Your firm stays responsible for safeguarding and your team approves every result. Safeheld does the daily work, applies the rules for your licence and keeps the evidence, so approval takes review rather than preparation.
What if a figure is missing?
Safeheld marks the result as figures missing rather than guessing, for example because no liability figure was recorded for the deadline or no licence covering the activity is recorded. Safeheld never shows a pass it cannot prove. It states what is missing.
Which funds count?
Only accounts and assets that qualify under the entity's rule. In the UK that means an acknowledgement letter on file. Elsewhere each account carries its recorded legal form. Funds in a different currency are not converted to fill a gap.
How are rules kept current?
Each rule set is versioned with its citations and effective dates. A change is drafted, reviewed and approved by a named person with two-step verification before it takes effect, and earlier results keep the version they used.
What happens when there is a shortfall?
A breach is opened with its deadline and materiality, and a top-up is proposed with the amount. In the UK the notification letter is prepared. The top-up is recorded against the position once the bank confirms payment.
Can auditors, banks and regulators see the evidence?
Yes, through read-only access, each with its own view. Locked records carry a unique code that anyone can check at safeheld.com/verify.
Is the FCA return filed automatically?
No. It is produced ready to file, and your team approves and submits it in My FCA. Every other regulator's report is prepared in that regulator's structure for your team to file in its portal.