Reasonable assurance report without statutory audit

We confirm that to the best of our knowledge and belief, and having made appropriate enquiries of other directors and officials of the firm:

  1. We acknowledge and have fulfilled our responsibilities, as set out in the terms of the engagement, for ensuring that the firm complies fully with the requirements of the Financial Services and Markets Act 2000 and for establishing and maintaining adequate accounting and other records and internal control systems to comply with the applicable provisions of the FCA’s handbook.
  2. There have been no events or conditions since the period end that would impact on the ability of the firm to continue to meet the threshold conditions or continue as a going concern. Should such events or conditions occur prior to your signature of the reasonable assurance report we will advise you immediately.

Information provided

  1. As agreed in the terms of engagement, we have provided you with: 
    1. Access to all information of which we are aware that is relevant to the preparation of the reasonable assurance report such as records, documentation and other matters; 
    2. Additional information that you have requested from us for the purpose of the reasonable assurance report; and 
    3. Unrestricted access to persons within the entity from whom you determined it necessary to obtain evidence. 
  2. We have disclosed to you all information in relation to fraud or suspected fraud that we are aware of and that affects the entity and involves:
    1. Management; 
    2. Employees who have significant roles in internal control; or 
    3. Others where the fraud could have a material effect on the assurance report.
  3. We have disclosed to you all known instances of non-compliance or suspected non-compliance with:
    1. the Financial Services and Market Act 2000 (FSMA 2000);
    2. the Money Laundering Regulations;
    3. the FCA rules; or
    4. other laws and regulations whose effects should be considered when preparing the reasonable assurance report; or any other circumstances that could jeopardise the authorisation of the firm under FSMA 2000.

    We have also notified you of the actual or contingent consequences which may arise from such non-compliance, including any potential effects on the firm’s ability to conduct its business.  

    Where applicable - We confirm, to the best of our knowledge and belief, that the breaches of CASS rules, as recorded on the breaches schedule, includes all breaches we have identified as having existed during the period covered by your report.

  4. We have provided you with a full list of bank accounts maintained by the company including details of all client money accounts.
  5. Where applicable - We confirm that the firm did not hold any mandates as covered by CASS 8.
  6. Where applicable - No client money was / custody assets were administered or held.
  7. All complaints have been drawn to your attention.
  8. We have made available to you all correspondence and notes of meetings with the FCA which are relevant to your examination.
  9. Where applicable - We confirm that where risk transfer agreements are in place with insurers, and the monies received from the client in respect of these insurers are treated as client money, that written agreement has been obtained from the insurer to co-mingle the premiums with client money in a client money account.
  10. We confirm that as far as we are aware:
    1. no services have been provided to us or our affiliated entities by RSM network firms and their related entities that we have not already informed you of;
    2. no gifts, hospitality, favours, donations or sponsorship have been exchanged between us or our affiliated entities and RSM network firms and their related entities that we have not already informed you of;
    3. no employment relationships exist between us or our affiliated entities and partners or employees of RSM network firms and their related entities we have not already informed you of; and
    4. no other business or personal relationships exist between us or our affiliated entities and RSM network forms and their related entities we have not already informed you of.

    11. The related entities of RSM network firms are as set out in the list provided.

We acknowledge our responsibility for the design, implementation and maintenance of internal control to prevent and detect fraud and error and we believe we have appropriately fulfilled those responsibilities.

We confirm that we have taken all the steps that we ought to have taken as directors in order to make ourselves aware of any information relevant to compliance with CASS rules and to establish that it has been communicated to the CASS auditors.

We confirm that, as far as we are aware, there is no information relevant to compliance with CASS rules of which the CASS auditors are unaware. We confirm that the above representations are made on the basis of enquiries of management and staff with relevant knowledge and experience (and, where appropriate, of inspection of supporting documentation) sufficient to satisfy ourselves that we can properly make each of the above representations to you.