Client Money Handling Procedures

Client Money Handling Procedures 2025

Definition of Client Money

The RICS Client Money Handling – 1st Edition October 2019, defines Client Money as Money of any currency (whether in the form of Cash, Cheque or Electronic Transfer) that

A 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; but

Excluding fees paid in advance for professional work agreed to be performed, and clearly identifiable as such, unless the fees are for works undertaken as a property agent as defined by the rules of the RICS client money protection scheme for property agents

Topics:
How and Where Money is Held;
Pooled Client Money Account;
Discreet Bank Account;
Access to Funds
Payment of Funds into Client Account
Controls for Authorisation of Payments from a Client Account
How Interest and Bank Charges are Handled
Payment of Invoices
Reconciliation of Accounts
Unidentified Payments
Information Provided to Clients about Monies Held on their Account

How and Where Money is Held

As part of the Royal Institution of Chartered Surveyors (RICS) professional statement (client money handling), effective from 1 January 2020 and internal due diligence, client money held or received by Graham + Sibbald UK LLP is either banked into a general clients account, a designated discreet account or held in a client – controlled bank account.

A general clients bank account is a Graham + Sibbald UK LLP Client Account which holds pooled client money belonging to more than one client. A discrete bank account is a client name bank account which holds client money belonging to a single client. Graham + Sibbald UK LLP will also hold virtual bank accounts for client, service charge sinking funds and tenant deposits.

Client monies are held separately from Graham and Sibbald’s own monies, are easily identifiable and immediately available. Within the general clients bank account, each clients money is recorded in individual client ledgers to maintain segregation of funds. Client money is held in an appropriate banking institution, regulated in the UK and authorised by the relevant regulatory body

Pooled Client Money Account

All client money is held within a client money bank account with RBS / NatWest. The bank will not be able to use any money held in the client bank account to settle any sum owed to it by Graham and Sibbald or any other third party. The bank will also not be able to combine any client money bank account with any other account nor have any right of set off or counterclaim against money on the client money bank account. Graham + Sibbald UK LLP have exclusive control over client money.

Discreet Bank Account

All client money is held within a discreet bank account with RBS / NatWest. Such money is held separately from any monies held for any other clients or for Graham and Sibbald. The bank will not be able to use any money held in the client bank account to settle any sum owed to it by Graham + Sibbald UK LLP or any other third party. The bank will also not be able to combine any client money bank account with any other account nor have any right of set off or counterclaim against money on the client money bank account. Graham + Sibbald UK LLP have exclusive control over client money.

Access to Funds

Signatories are at level Associate and above. Approvals to execute electronic payments from the client account will be restricted to signatories. Partners may not sign cheques or approve transfers drawn against hard copy invoices soley authorised by them.

Payment of Funds into Client Account

All cheques received by post are logged and banked on the day of receipt, where possible, and allocated to the appropriate client money account when cleared. Graham + Sibbald UK LLP do not accept cash payments. All unidentified funds are reviewed as soon as possible and no later than 3 months from receipt at which time they will be allocated or returned.

Controls for Authorisation of Payments from a Client Account

A withdrawal from a client account can only be made after a specific authority has been approved by a signatory in accordance with the bank mandate or the firm’s procedures and systems. All payment requests must be accompanied by supporting evidence that has been checked and authorised. Segregation of duties in the client accounting function is in place to prevent data tampering with the payment process.

How Interest and Bank Charges are Handled

The client accounts is an interest bearing, instant access account and Graham + Sibbald UK LLP will cover transactional banking and account maintenance charges associated with the day-day operation of such account (not including overdrawn penalties which will be borne by the client).

Graham + Sibbald UK LLP is entitled to retain any interest earned through the aggregation of various client accounts to offset general bank charges and administration costs associated with operating the bank accounts.

Interest generated from the virtual accounts will be credited to the designated virtual account.

Payment of Invoices

There will be a payment run weekly for supplier invoices.
Payment runs will be approved by the appropriate client account manager for relevant client.
The BACs file is generated by the Accounts Team, which will be reviewed by relevant signatory to authorise with all supporting documentation.
Any urgent payments can be made outside of the payment run.
All payments are made by 1 Day faster payments unless specific client or senior approval.

Reconciliation of Accounts

Bank accounts are reconciled on a monthly basis where appropriate. The pooled account is reconciled using a three- way reconciliation between the bank, general ledger/ cash book and individual client ledgers as required by RICS.

Unidentified Payments

Should we receive any funds that are unable to identify, we will do our best to understand which client they relate to and upon investigation, reimburse the client as soon as possible if necessary. Any unidentified funds we will endeavour to identify. If someone claims the payment, upon proof of payment we will allocate it accordingly, if within 3 months, no one has claimed the monies, despite all avenues of investigation having been exhausted, (emails, letters, calls etc), we will return the payment back to the originator of where the funds came from. If it is not possible to return the payment, we will hold on to it for 3 years at which point we will donate to a registered charity of our choice. As part of this we will obtain a receipt and indemnity from the charity that would reimburse for the firm for payment of the monies if a beneficiary is subsequently identified.

Information Provided to Clients about Monies Held on their Account

Reporting and frequency requirements are agreed and documented with the client.

This document was last reviewed 10th April 2025