General controls

At all times we ensure:

• relevant 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 client money handling procedures.
• 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

At all times we ensure:

• that our clients’ money is held in a client bank account separate from all other monies and that client money is available on demand.
• the client bank account is correctly titled to distinguish the account 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

At all times 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.
• our systems provide details of all money received into and paid from our client account and show a running balance of all client money held in that account.
• our systems identify all receipts and payments to the client to which they relate.
• accounting records are completed chronologically and promptly.
• the current balances at the total and client levels are always available.
• all ledgers have the client name and an appropriate description, e.g. the property address.
• 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. 
• we complete a reconciliation at least once every month where clients’ money is held in a general client account.
• reconciliations are performed by a Principal

Controls over the receipt of client money

At all times we ensure that:

• 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.

Controls over the payment of client money

At all times we ensure that:

• checks are made to ensure that sufficient funds are held on behalf of the relevant client before payments are made.
• a copy of the bank mandate is held and is up to date.
• adequate authorisation and supervision procedures are in place for payments made by bank transfer and electronic methods.
• all payment requests have supporting evidence and that documentation has been authorised in advance by a Principal or other appropriate person.
• effective controls are in place over the setting up of new supplier accounts on the system.
• cash and cheque payments are avoided.