Client Money Handling Procedure
The purpose of this document is to set out Cooper and Tanner 1908 Limited Client Money Handling procedures. The internal controls and procedures have been designed and implemented to follow best practices and RICS regulations.
Definition of Client Funds
Money of any currency (whether in the form of cash, cheques, draft, or electronic transfer) that:
- A RICS-regulated firm holds for or receives on behalf of another person, including money held by a regulated firm as a stakeholder, and
- Is not immediately due and payable on demand to the RICS-regulated firm for its own accounts, but
- Excluding fees paid in advance for professional work agreed to be performed and clearly identifiable as such unless the fee is for work undertaken as a property agent as defined by the rules of the RICS client money protection scheme for property agents.
- All client bank accounts are correctly titled to distinguish the accounts from an office or any other account
- All our clients’ money is held in one or more client bank accounts separate from all other monies and that client money is available on demand
- The bank accounts are held by a UK banking institution, which is regulated by the Prudential Regulation Authority, and the Financial Conduct Authority
- We have obtained written confirmation from the bank of the client account conditions
- We advise clients in writing of the bank account details and agree the terms of the account handling, including arrangements for interest and charges
- We obtain written consent from our clients regarding retention of interest.
- We use a suitable software package to manage client money effectively
- Employees have a clear segregation of duties and responsibilities, with appropriately qualified individuals overseeing the client accounting function
- Our systems provide details of all money received into and paid from all client accounts and show a running balance of all client money held in that account
- All accounting records are completed chronologically and promptly
- The current balances at the total and client levels are always available
- Processes are in place to prevent any overdrawn balances on client ledgers
- Controls are in place to deal with unidentified client money. Any funds are held securely for three years, before being donated to a registered charity
- A ‘three-way’ reconciliation is performed every month where clients’ money is held in a general client account
- All reconciliations are reviewed and signed off by the Head of Finance or director
- Electronic receipts are reviewed daily, and where possible allocated to the appropriate client ledgers
- Any cheques received are logged and recorded on the day they are received by the client accounting team, and cheques are banked on a weekly basis
- Any unidentified funds are investigated as soon as possible. If it is not possible to identify what the money relates to it will be returned to the sender within 1 month of receipt
- Unbanked client money receipts are kept secure.
- No payments are made unless there are sufficient funds held to cover the payment
- A member client accounting team uploads a request for payment with supporting evidence and documentation, where it is approved by a company director or associate
- Effective controls are in place over setting up new suppliers account on the system
- All payments are made by electronic transfer, wherever possible, and are approved by the Head of Finance and a director
- Segregation of duties is in place between the individuals involved in the client accounting, accounts payable & payment approvals.
Our aim is to ensure that clients’ money can be clearly linked to the clients to whom it belongs and is protected on their behalf at all times.
Should clients’ money be misappropriated, the firm will inform our governing body, the RICS and, where appropriate, the police and our insurers.
How and where client money is held
Client accounting systems and controls
Timescale for payment into client accounts
Authorisation of payments from a client account