Cashroom Manager Assessment Q&A

The Client Protection Sub-Committee (CPSC) has identified that very poor levels of knowledge of the Accounts Rules has been a significant factor in a number of serious compliance failures it has dealt with. In response to this it is anticipated that an assessment of cashroom manager knowledge of the Accounts Rules will provide information to assist the Society's Financial Compliance Department in assessing which practice units pose the greatest risk of non-compliance with the Accounts Rules. Practice units where adequate levels of knowledge are not demonstrated by the cashroom manager will be prioritised for inspection to assess whether actual compliance with the Accounts Rules is satisfactory or not.

The assessment process is expected to bring the following benefits:

• An increased awareness of the requirements and importance of the Accounts Rules, including at new practice units
• Better knowledge and confidence levels amongst cashroom managers, including at new practice units
• A positive impact on levels of compliance and risk management at practice units and a reduced risk of serious non-compliance
• Further enhancement of the reputation of the Scottish profession
• Contributing to a more effective and risk-based inspection process
• Accounts Rule guidance and training material can be updated to address key areas of weakness identified by the process.

Except for new cashroom managers, the rule does not fix a requirement for the extent to which cashroom managers are to complete an assessment and does not set a required frequency. Instead, the approach and priorities for completion of assessments will be agreed with the Client Protection Sub-Committee. New cashroom managers and new practice units will however clearly be a continuing priority for the process.

The CPSC will monitor the frequency and coverage of cashroom manager assessments and will assess as part of a risk-based approach whether the coverage is adequate and achieving the objectives of the process.

For new Cashroom Managers

When the Society is notified of your appointment to the role of cashroom manager, you will be contacted by the Society's Financial Compliance team with details of how to access the assessment. This requires to be completed within 12 months of your appointment to the role.

For existing Cashroom Managers

The Financial Compliance team will contact you to advise if you have been selected to complete the assessment. Some cashroom managers will be selected due to risk factors associated with the practice unit, but this will not be the case for all selections. Factors which may influence the selection process will include:

• The compliance history of the practice unit
• The compliance history of individual cashroom managers
• Direction from the Client Protection Sub-Committee
• Thematic/risk factors – eg: a focus on different types of practice units such as consideration of the size of a practice unit or the level of client funds held pe principal

Failing an assessment will in itself, not result in disciplinary action.

As noted above, assessment results will be used to assist the Society's Financial Compliance team in risk-based prioritisation of practice units for inspection. As is the case currently, when significant non-compliance with the Accounts Rules is identified on inspections, this can result in disciplinary action.

The Client Protection Sub-Committee (CPSC) may decide that the assessment should be repeated in some or all cases where the assessment is initially failed. The decision of the CPSC in such cases may be influenced by the levels of compliance demonstrated on the subsequent inspection of the practice unit.

A Cashroom Manager who fails the assessment will be expected to take steps in accordance with Rule B6.13.2 to take reasonable steps to improve their knowledge such as further review of up-to-date guidance and example assessment questions.

The assessment questions will be prepared by members of the Society's the Financial Compliance team and agreed with the Client Protection Sub-Committee. Answers will be developed for the questions produced. Marking will be in accordance with these answers.

Questions will be set at a level which is necessary to assess whether cashroom managers are able to achieve compliance with their obligations to secure their practice unit’s compliance with the accounts rules and to supervise the relevant staff and systems of the practice unit.

We aim to create an online assessment which cashroom managers can complete remotely. It is envisaged that a unique login and link will be issued to each cashroom manager required to sit the assessment, with a deadline for completion of the assessment.

New cashroom managers who are also new principals will have received an introduction to the Accounts Rules at the Society's mandatory Practice Management Course.

Existing cashroom managers may wish to familiarise themselves with the Accounts Rules Guidance available on the Society’s website. This will be updated to fully reflect the new rules once they are approved.

Example assessment questions will be made available on the Society's website. Past assessment questions will also gradually be made available on the website.

The Society does not require cashroom managers to obtain a relevant qualification, although we are aware that some cashroom managers do value this approach.

No. The assessment process will be part of the mandatory Accounts Rules. Non-completion will be a breach of the rule which would be considered by the Client Protection Sub-Committee.

The information produced by the assessments is only part of a risk-based approach. Many other factors will continue to be considered when assessing which practice units should be prioritised for inspection.

Cashroom managers are already required by Accounts Rule B6.13.2 to acquire/maintain the skills necessary to discharge their responsibilities. The assessment process simply formalises the process of demonstrating that the necessary skills have been acquired and should not be viewed as a significant additional burden.

We believe that most cashroom managers and candidates to be cashroom managers will recognise the importance of the role and understand the benefits available to them and the profession through the assessment process. The assessment process does not increase the obligations to cashroom managers to achieve compliance with the Accounts Rules by the practice unit.

No. The responsibilities of a cashroom manager include supervision of cashroom staff, arranging for the training of these staff and taking steps to ensure the practice unit’s compliance with the Accounts Rules. It is part of a cashroom manager's role to ensure that the staff employed in cashroom roles are competent (for example, through examination, experience etc). We expect that the assessment process will add to the ability of cashroom managers to deliver this part of their role.