The CAMP is required to consider inter alia:
a) details of a firm’s business model, operational structures and governance arrangements;
b) the range of investment services provided and type of client assets held by a firm;
c) a client asset applicability matrix (mapping of product and service offering and where client assets could arise); - new (see below)
d) the risks to the safeguarding of client assets including those specific to the particular business model of the firm;
e) the processes and controls in place to mitigate the risks to the safeguarding of client assets;
f) information to facilitate the distribution of client assets; particularly in the event of the firm’s insolvency;
g) where a firm outsources to another party any activity related to the safeguarding of client assets, including the performance of the reconciliation or the daily calculation;
h) the basis and criteria that will be used by a firm to determine materiality such as escalations and notifications in respect of client assets;
i) such other matters as may be determined by the Firm from time to time; and
j) the location of a Firm’s internal client asset breach and incident log – new