It outlines the regulatory role of client and insurer or market counterparty TOBAs, highlights common weaknesses such as missing or unclear agreements and inconsistencies with operational practice, and sets out good-practice arrangements for risk assessment, ownership, training, oversight, independent review, change management and day-to-day controls. Overall, it emphasises that TOBAs should be managed throughout their lifecycle as a core part of a firm’s ongoing client money governance framework, rather than treated solely as legal documents or reviewed only for the annual CASS audit.
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