Client Money Handling Policy

1. Purpose

This Client Money Handling Policy sets out the procedures and controls adopted by Chandler Garvey in relation to the receipt, handling, management, protection, and accounting of client money in accordance with the requirements of RICS Professional Standards and all applicable legislation and regulatory obligations.

The purpose of this policy is to:

• Protect client funds at all times;
• Ensure transparency and accountability;
• Maintain compliance with RICS Rules of Conduct and professional standards;
• Reduce the risk of fraud, error, or misappropriation;
• Ensure accurate and timely accounting to clients.

This policy applies to all partners, directors, employees, consultants, and contractors involved in the handling or administration of client money

2. Definition of Client Money

For the purposes of this policy, “client money” means money of any currency:

• Held or received on behalf of a client; and
• Controlled by Chandler Garvey in the course of providing property management, agency, or professional services.

Examples include:

• Commercial rents;
• Service charge monies;
• Insurance rent recoveries;
• Tenant deposits (where applicable);
• Maintenance and reserve funds;
• Monies held for suppliers or contractors;
• Other stakeholder funds.

Client money does not include fees paid to Chandler Garvey for its own services once properly invoiced and transferred to the office account.

3. Regulatory Compliance

Chandler Garvey shall comply with:

• RICS Professional Standard: Client Money Handling;
• RICS Rules of Conduct;
• UK Anti-Money Laundering legislation;
• Data protection legislation;
• Relevant accounting and banking regulations.

Where there is any conflict between this policy and applicable legislation, the legislation shall prevail.

4. Client Accounts

4.1 Segregation of Funds

All client money shall be held in one or more designated client bank accounts separate from Chandler Garvey’s own office or trading accounts.

Client accounts shall:

• Be clearly identified as “Client Account”;
• Be held with a recognised UK banking institution;
• Be used exclusively for client money transactions.

Under no circumstances shall client money be mixed with office funds unless specifically permitted for bank charges or authorised temporary transfers.

4.2 Interest

Interest earned on client money shall be handled in accordance with the terms agreed within the client management agreement and any applicable statutory requirements.

Chandler Garvey reserves the right to retain interest where:

• The amount is nominal; and/or
• Administrative costs exceed the interest accrued.

This shall be disclosed within client terms of engagement.

5. Receipt of Client Money

All receipts of client money shall:

• Be recorded promptly and accurately;
• Be allocated to the correct property and client ledger;
• Be supported by appropriate documentation;
• Be banked without undue delay.

Where cash receipts are unavoidable, enhanced verification and recording procedures shall apply.

Electronic transfers are the preferred method for all client money transactions.

6. Payments from Client Accounts

Payments from client accounts shall only be made:

• For legitimate property-related expenditure;
• In accordance with the management agreement or client instructions;
• Following appropriate authorisation procedures.

Examples include:

• Contractor invoices;
• Service charge expenditure;
• Insurance premiums;
• Refunds or distributions to landlords;
• Tax payments where applicable.

All payments must:

• Be supported by invoices or written authority;
• Be approved by authorised personnel;
• Be recorded within the accounting system.

Dual authorisation shall apply for electronic payments above internally determined thresholds

7. Accounting Records and Reconciliations

Chandler Garvey shall maintain accurate and up-to-date accounting records for all client money transactions.

Records shall include:

• Cash books;
• Client ledgers;
• Bank statements;
• Supporting invoices and documentation;
• Reconciliation records.

Client accounts shall be reconciled:

• At least every five weeks; and
• Promptly investigated where discrepancies arise.

Reconciliations shall be independently reviewed and approved by a senior member of staff.

Accounting records shall be retained in accordance with legal and regulatory retention requirements.

8. Controls and Security

Chandler Garvey maintains internal controls designed to safeguard client money, including:

• Segregated accounting systems;
• Restricted banking access;
• Password-protected payment systems;
• Dual authorisation controls;
• Staff segregation of duties;
• Regular management review;
• Fraud prevention measures;
• Cybersecurity controls.

Any suspected fraud, theft, or irregularity shall be reported immediately to senior management and investigated promptly.

9. Client Reporting

Clients shall receive regular statements and reports detailing:

• Income received;
• Expenditure incurred;
• Balances held;
• Reconciliations where appropriate.

Reporting frequency shall be agreed within the management agreement.

Chandler Garvey shall respond promptly to reasonable client requests for information relating to client money held.

10. Overdrawn Balances and Deficits

Client accounts shall not be allowed to become overdrawn.

Where a deficit occurs due to error or timing differences:

• Immediate corrective action shall be taken;
• The matter shall be escalated to senior management;
• A full audit trail shall be maintained.

Under no circumstances shall one client’s funds be used to cover another client’s obligations.

11. Anti-Money Laundering (AML)

Chandler Garvey operates anti-money laundering procedures in accordance with applicable legislation.

This includes:

• Client due diligence;
• Verification of identity;
• Source of funds checks where required;
• Ongoing monitoring;
• Suspicious activity reporting.

Employees shall receive periodic AML training appropriate to their role.

12. Staff Responsibilities and Training

All staff handling client money must:

• Understand this policy;
• Follow established procedures;
• Complete relevant training;
• Report concerns immediately.

Senior management is responsible for:

• Oversight of compliance;
• Maintaining effective controls;
• Reviewing procedures regularly.

13. Complaints Handling

Any complaint relating to client money shall be handled in accordance with Chandler Garvey’s formal complaints procedure.

Clients shall be informed of:

• Internal complaint procedures;
• Their rights to refer unresolved complaints to an independent redress mechanism where applicable.

14. Professional Indemnity and Client Money Protection

Chandler Garvey shall maintain:

• Appropriate Professional Indemnity Insurance (PII); and
• Any required Client Money Protection arrangements in accordance with regulatory obligations.

Evidence of cover shall be made available upon reasonable request.

15. Policy Review

This policy shall be reviewed:

• Annually;
• Following changes to RICS requirements;
• Following significant operational or regulatory changes.

Any amendments shall be approved by senior management.

16. Contact Information

For queries relating to this policy or the handling of client money, please contact:

Chandler Garvey Ltd
Joanna Kearvell
Managing Director

[email protected]