Client Money Handling Policy
RA Jackson & Son LLP
1. Purpose
This policy sets out RA Jackson & Son LLP’s principles and procedures for handling client money to ensure compliance with internal controls and RICS regulations to protect client funds from misappropriation or loss.
This document should be read in conjunction with RICS Professional Standards and Guidance UK, Client Money Handling.
2. Scope
This policy applies to all employees, contractors, agents, and representatives of RA Jackson & Son LLP who receive, hold, or manage money on behalf of clients. It includes money received for services, deposits, disbursements, rent, or any other reason.
3. Definition of Client Money
Client money, as defined in the RICS Professional Standards and Guidance UK, Client Money Handling is money that a firm holds or received on behalf of another person, including money held by a regulated firm as a stakeholder.
Client money belongs to clients but is held by the business temporarily. This includes but is not limited to :
- Rent received on behalf of landlords
- Tenant deposits
- Disbursements from clients for third-party services
- Refundable client balances
4. Client Money Bank Account(s)
- All client money held or received by RA Jackson & Son is to be held in either a) an undesignated client account or b) a discrete client account separate from the firm’s own operational accounts.
- The account(s) will be:
- Recognised by the bank as a Client Money Account
- Subject to safeguards under the Financial Services Compensation Scheme (FSCS), where applicable
- Reconciled at least monthly to ensure accuracy
5. Receiving Client Money
- All incoming client funds are recorded in the accounting system upon receipt.
- The source, purpose, and intended use of the funds must be clearly documented.
- Cash payments should be discouraged. Where cash or cheques are received they should be paid into Lloyds Bank PLC and a receipt kept with daily banking record.
6. Disbursing Client Money
- Disbursements may only be made:
- In accordance with the client’s written instructions or contract
- For agreed disbursements (e.g. legal fees, third-party costs including contractor payments, payment of RA Jackson & Son fees where agreement in advance is held.)
- When returning balances to the client
- Payments must be authorised by an appropriately designated staff member.
Office staff have the ability to view Bank Statements to identify payments and receipts.
Appointed office staff have the ability to upload payments for authorisation.
Partners are responsible for authorising all payments, transfers and Bank mandate changes.
7. Reconciliations and Record-Keeping
- Bank reconciliations of client accounts will be carried out as a minimum monthly.
- Reconciliation records will be reviewed and signed off by a senior manager.
- All records relating to client money must be retained for a minimum of six years.
- In line with RICS regulations R A Jackson & Son carry out a three-way reconciliation between bank statement, general ledger and client ledgers.
8. Interest on Client Money
- Interest will be handled in accordance with the client agreement.
- Where applicable, a fair and reasonable rate of interest will be applied, or the firm may retain interest earned as agreed with the client.
- All commercial deposits held on behalf of tenants will accrue interest.
9. Client Money Protection (CMP)
- RA Jackson & Son LLP is a member of RICS Client Money Protection Scheme. This scheme provides protection, as a last resort, in instances where an RICS Regulated firm is unable to repay a client's money, up to the limits and exceptions set out in the scheme rules.
- Details of our CMP membership and certificate are available upon request and displayed at our office and on our website.
10. Breach Reporting and Rectification
- Any discrepancies or breaches must be reported to a partner immediately.
- Corrective action must be taken without delay, and clients notified if appropriate.
- Serious breaches may need to be reported to the relevant regulator or professional body.
11. Unidentified Funds
Unidentified funds should be investigated immediately. If it is not possible to identify the funds through all available methods of investigation (phone, email, letters, etc) it will be returned to the sender. If it is not possible to return to sender RA Jackson & Son LLP will retain the funds for a period of 3 years after which it may be donated to a registered charity of our choice.
12. Staff Responsibilities and Training
- All relevant staff must be trained in this policy and understand their responsibilities.
- Periodic refresher training will be provided.
- Breach of this policy may result in disciplinary action.
12. Policy Review
This policy will be reviewed at least annually or sooner if there are changes to relevant legislation, regulatory rules, or the business’s structure or operations.
Signed:
James Barlow
Partner