Client Money Handling Policy

1. PURPOSE

The aim of this Policy is to set out Davidson & Robertson’s (‘D&R’, ‘us’, ‘we’, ‘our’) rules and procedures for handling client money, in line with the professional standard issued by the Royal Institution of Chartered Surveyors (RICS).

2. SCOPE

This Policy covers all client monies and associated client accounts, both discrete and general, managed by D&R on behalf of clients as agreed per our terms of engagement.

3. DEFINITIONS

Client money:
Money of any currency (whether in the form of cash, cheque, draft or electronic transfer) that:
• we hold or receive on behalf of another person, including money held by a regulated firm as stakeholder, and
• is not immediately due and payable on demand.

Client money account:
An account in the name of an RICS-regulated firm, a wholly owned subsidiary company of the firm or an appropriately contracted third-party transaction service provider, holding client money that belongs to:
• a single client of the firm (discrete client money account), or
• more than one client of the firm (general client money account).

4. RESPONSIBILITIES

Overall responsibility to manage client monies appropriately is that of the Directors. The Finance Director, supported by the Finance team, is responsible on a day-to-day basis.

5. HOW AND WHERE CLIENT MONEY IS HELD

Client money held or received by D&R is either banked into a general clients’ bank account or a discrete client account.

Client monies are held separately from D&R’s own monies, are easily identifiable and immediately available. Should a single receipt containing both Client and D&R funds it will be lodged into a general client bank account to be separated before transferring to the appropriate accounts. Client money is held in a regulated banking institution, namely Royal Bank of Scotland. Within the general client account, each client’s money is recorded in individual ledgers to maintain the segregation of funds.

6. ACCESS TO FUNDS AND AUTHORISATION OF PAYMENTS FROM A CLIENT ACCOUNT

Any withdrawal of moniesfrom a client account is subject to dual authorisation, whereby no individual member of staff can both set up recipient bank details and make a bank payment. Segregation of duties within the Finance team is in place.

All payment requests are supported by appropriate paperwork, verification and authorisation.

Internal approval levels and limits are in place to ensure all payments are authorised appropriately.

7. TIMESCALES FOR PAYMENT OF CASH INTO A CLIENT ACCOUNT

If cash and/or cheques are received by post, these amounts are logged and allocated on day of receipt where possible. They are banked on a weekly basis.

Any unidentified funds are reviewed promptly and certainly within 1 month from receipt. Suitable details will be recorded and an investigation undertaken to identify the owner of the funds as soon as possible.

8. HOW INTEREST AND BANK CHARGES ARE HANDLED

General client accounts are non-interest bearing. Any banking charges relating to the operation of general client accounts are covered by D&R.

9. RECONCILIATION OF ACCOUNTS

Bank accounts are reconciled, at a minimum, on a monthly basis. General client accounts are reconciled to individual client ledgers and discrete client accounts are reconciled to the client’s set of accounts.

10. INFORMATION PROVIDED TO CLIENTS ABOUT MONIES HELD ON THEIR ACCOUNT

Reporting requirements, including the frequency of any reports, are detailed within the terms of engagement agreed with the client.

11. POLICY IMPLEMENTATION AND AUDIT

This policy is published on the company’s internal SharePoint, on our website for our client’s information and available on request. The principles and standards in this policy are disseminated, discussed and shared during training sessions and briefings.

Regular audits of client money handling form part of the internal audit schedule.

12. DOCUMENTATION

This policy may be read in conjunction with the following documents:

• RICS Professional Standard Client Money Handling
• Royal Institution of Chartered Surveyors’ Rules of conduct

13. VERSION CONTROL AND OWNERSHIP

This policy will be reviewed at least annually from date of approval, or when deemed necessary by the CEO, Finance Director, Risk and Compliance Manager or other senior employee.