Client Money Handling Procedure
As an RICS Regulated Firm we will comply with the RICS Client Money Handling Requirements and ensure ongoing participation in the RICS Client Money Protection Scheme.
How and where client money is held
- All client monies are held in designated client money bank accounts, which Neil Douglas, as the RICS Regulated Firm has exclusive control, at a bank or building society authorised by the relevant banking regulatory authority.
- All client accounts clearly include the word ‘Client’ in the bank account title and have a mandate from the bank confirming the funds in the account are client funds.
- Dedicated client money bank accounts are held for each of our clients and include the name of the client in the account name, so are distinguishable from accounts held for other clients.
- The dedicated client account details are advised to clients on an ongoing basis by inclusion on the service charge demand.
- Client accounts are easily distinguished from Neil Douglas’ own business bank accounts and these business bank accounts are managed via a different accounting system.
Who has access to client accounts and how payments are authorised
- Access to client accounts is restricted to principals and senior employees.
- All payments are made in accordance with client’s written instructions or in accordance with the terms of our management agreement.
- All payments are authorised through our client accounts system and at the bank.
- Checks are made to ensure sufficient funds are held before making payments.
Receipt of monies into client accounts
- All sums received by cash or cheque are paid into a client account promptly.
- Any unidentified client money received is investigated, and prompt action is taken to identify it and return it. If the owner cannot be identified after three years from receipt and all avenues of investigation have been exhausted, it will be donated to charity on the basis that it will be reimbursed if the beneficiary is subsequently identified.
- Processes are in place to ensure that client accounts do not contain sums other than the whole or any part of client money paid into it.
- No office money will be held in a client account unless it is a mixed receipt of monies where the office money is awaiting transfer.
Interest and bank charges
- Interest earned on the client account is applied to that account.
- Bank charges are debited from the office account and recharged to clients in accordance with their management agreement.
Account reconciliation and availability of funds
- The money held in the client account is immediately available should it be required to be withdrawn and without penalty to the client.
- There are systems in place to prevent client accounts from being overdrawn.
- Monthly reconciliations of client bank accounts are completed and then signed-off by a principal or senior employee.
- A financial report, including cashbook and spend versus service charge budget, is provided to clients after every reconciliation.
- All client account accounting records are retained for six years.
Compliance
- Neil Douglas is registered with HMRC for Anti-Money Laundering supervision
- Neil Douglas is regulated by the RICS and a member of the RICS Client Protection Scheme
- We are committed to ensuring that any breach of mandatory requirements included in the RICS professional statement are recorded in detail, including any consideration of whether to inform RICS and any client affected by the breach.
- We will inform RICS, the client and our insurers if client money is misappropriated by any person.
