Client Money Handling Procedure

Introduction

The purpose of this document is to set out Michael Carrington Property Management’s (MCPM) Client Money Handling procedures, in particular the controls and procedures needed to observe best practice in the industry as per the RICS and TPI consumer standards. Specific attention must be made to the RICS Professional Statement, Client Money Handling 1 edition, st October 2019.

Definition of Client Money

Money of any currency (whether in the form of cash, cheque, draft or electronic transfer) that:

An RICS-regulated firm holds for or receives on behalf of another person, including money held by a regulated firm as stakeholder and
Is not immediately due and payable on demand to the RICS-regulated firm for its own account,

Excluding fees paid in advance for professional work agreed to be performed, and clearly identifiable as such, unless the fees are for
work undertaken as a property agent as defined by the Rules of the RICS Client Money Protection Scheme for Property Agents. Source;
Client Money Handling 1st edition, October 2019

How and where client money is held

Client money held by MCPM is banked into discrete and undesignated client bank accounts. Undesignated client bank account is set up
to hold client money for a single or multiple clients. For the discrete bank accounts, the name of the client is incorporated into the
account name as is the term, ‘client account’ to comply with best practice.
The banking systems currently used are HSBC and Lloyds.

Access to funds

MCPM staff have defined access to funds and the authorisation of payments in line with their individual roles and the set hierarch within
the company. This can be defined as follows;

Service Charge Accountants and Financial Administrators have the ability to allocate receipts and identify payments and upload them for authorisation
Accounts Payable have the ability to upload payments for authorisation
The Business Accounts Manager authorises all clients’ accounts payments with no limits
The Director of Finance is able to sign off all payments with no limits
The Founder is able to sign off all payments with no limits
The Business Accounts Manager is not able to set up contractors or amend payment details on existing suppliers
The Director of Finance and Founder are able to set up sub-contractors or amend payment details on existing suppliers

Timescales for receipting of cash and cheques into a client account

The Accounts Payables and Receivables team at MCPM log all monies received on the day of receipt and where possible allocate to the appropriate client money accounts. We do not accept payments via cheques. Any unidentified funds will be logged into the suspense account and if not identified within three months, the funds will be returned if the originator’s details are present.

Controls for authorisation of payments from a client account

A withdrawal from a client account, can only be made if;

We have permission through contract or direct instruction from the client to do so
All internal procedures have been followed in line with ‘Access to Funds’, set out above
Sufficient supporting evidence is provided and checked, so the payment can be validly made

How interest and bank charges are handled

MCPM’s discrete client accounts are interest bearing, instant access accounts. The maintenance and transactional banking costs are paid for by the clients; the maintenance costs are recovered on an annual basis. MCPM has agreed with Lloyds that an aggregated rate of interest is applied to all the client accounts. MCPM has agreed interest share rates with some of its clients in writing but not limited to letter, email communication or explicitly through the contract to split the interest. The interest will be receipted into the MCPM business account on a monthly basis and the proportion due to each client will be paid within five working days or as near to that deadline as possible.

Bank reconciliation procedures

All the client bank accounts are reconciled monthly. We do this by performing a three-way reconciliation between the bank statements, cash books and the individual client ledgers. All bank reconciliations are reviewed by the relevant client accountant.

Providing information to clients about monies held on their accounts

As per the RICS Code, 4 Edition, we provide in writing to all clients the details of account and banking institution in which their funds are held. In addition, for some larger clients, we provide further client money information i.e. balance and a review of their spend against budget on a quarterly basis.

Approved by: Sherif Mankarios
Director of Finance
Dated:16/09/2026