Client Money Handling Procedures
Carter Oliver will preserve the security of clients’ money entrusted to its care in the course of its practice or business.
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 and in particular, in the following circumstances:
- Misappropriation by any party
- Transfer of client money to another organisation
Should clients’ money be misappropriated, the company will inform where appropriate, the police and our insurers.
- Employees have clear segregation of duties and responsibilities and that a principal or appropriately qualified individual oversees the client accounting function.
- That we employ competent and knowledgeable staff who are responsible for processing clients’ money and who are familiar with The Property Redress Scheme Rules.
- That our accounting systems and client data are securely controlled and protected.
- That our computer systems are adequately protected for access, firewalls, backups and disaster recovery.
- There is adequate cover for holiday and long term absence.
- Principals cannot and do not override controls surrounding the accounting systems.
- All departments apply the same level of controls in relation to the client accounting function.
Client bank accounts
- That our clients’ money is held in one client bank account separate from all other monies and that client money is available on demand.
- Any client bank accounts are correctly titled to distinguish the accounts from an office or any other account.
- We have obtained written confirmation from the bank of the client account conditions.
Client accounting systems and controls
We ensure that:
- Accounting records and systems are appropriate to the nature and volumes of client account transactions. We use a suitable software package to manage client money effectively.
- The current balances at the total and client levels are always available.
- Overdrawn balances on client ledgers are prevented by the systems or controls in place and where they do occur are investigated and rectified immediately.
- Adequate controls are in place over unidentified client money to ensure that such funds are kept securely. The clients are located and reimbursed as soon as possible. Such funds held for more than six years are donated to a registered charity.
- A central list of client bank accounts is maintained including dates of opening and closing accounts.
Controls over the receipt of client money
We ensure that:
- Only a Principal or appropriate staff independent of accounting staff open incoming post.
- Procedures exist to identify and distinguish between clients’ and office money.
- Mixed monies are initially paid into the client account and the office element paid in the office account when the receipt has cleared the bank.
- Fees received in advance for professional work not yet billed are paid into a client account pending completion of the work.
Controls over the payment of client money
We ensure that:
- Checks are made to ensure that sufficient funds are held on behalf of the relevant client before payments are made.
- Adequate authorisation and supervision procedures are in place for payments made by cheque, bank transfer and electronic methods.
- cash payments are avoided.