General
Client money is protected through the RICS Client Money Protection Scheme and is held in accordance with the scheme rules.
Hair & Son follows RICS mandatory and best practice guidelines as set out in RICS, Client Money Handling, reissued October 2022. Procedures are reviewed on a regular basis.
What is client money?
Client money relates to money of any currency, whether in the form of cash, cheque or electronic transfer, which is:
- Held or received on behalf of another person, including money held by a regulated firm as stakeholder.
- 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, detailed in Client Money Handling as above.
Where do we hold client money?
Client money is held in one of the following:
- A discrete bank account – a Hair & Son bank account held in the name of a single client.
- A general client bank account – a Hair & Son bank account holding client money on behalf of more than one client.
Hair & Son also transacts on behalf of clients on client controlled bank accounts. These are not covered by the RICS client money protection scheme. Where the client requests that money is held in this type of account, it must be set up by the client and cannot be a discrete Hair & Son held client account.
In the case of discrete and general client accounts the client money is under the exclusive control of Hair & Son and the bank accounts are held by a UK banking institution, with a minimum rating of BBB+ which is regulated by the Prudential Regulation Authority, the Bank of England and the Financial Conduct Authority.
How do we hold client money?
- We keep client monies separate from Hair & Son’s own monies at all times.
- We hold all client money in a client money account over which Hair & Son has exclusive control.
- Monies are identifiable and immediately available.
- Within a general clients’ bank account, funds belonging to each client are recorded individually.
Access to funds
- Signatories are restricted to Partners and senior accounts department staff.
- All payments and internal transfers require dual signatories, one of whom must be a Partner.
- New signatories to client money accounts also require dual signatories, one of whom must be a Partner.
Payments into a client account
- Hair & Son does not accept cash on behalf of clients.
- Cheques are logged on the day of receipt and banked within 3 working days of receipt.
- Cheques are credited to the appropriate client money account.
Payments from a client account
- Each client’s money is only used in relation to that client.
- All payment requests must be accompanied by supporting evidence that has been checked and approved (this includes appropriately approved invoices and verified payee bank details).
- Segregation of duties in the client accounting function is in place to prevent unauthorised activity/data tampering within the payment process.
Interest and bank charges
- The general client bank account is an instant access account but is not interest bearing.
- The discrete client bank accounts are instant access accounts and most are interest bearing.
- Hair & Son may charge the client transactional banking and account maintenance charges associated with the operation of a discrete client bank account.
- Charges in respect of a general client account will be borne by Hair & Son.
- Interest earned on a discrete client bank account will be retained in that account.
- Interest earned in respect of a general client account will be retained by Hair & Son and is used to offset the account maintenance and transactional banking costs.
Reconciliation of bank accounts
- General client bank accounts and some discrete client bank accounts are reconciled on a monthly basis. Other discrete client bank accounts are reconciled on a quarterly basis.
- All bank reconciliations are reviewed and signed off by a Partner.
- Where receipts are not promptly cleared through the bank account, they are reviewed on a monthly basis with appropriate action taken. Where expenditure does not clear within 12 months they will be cancelled and the funds credited back to the client, pending investigation and replacement.
- Discrete and client-controlled bank accounts – Bank statement, system generated ledger and list of dated reconciling items presented for review and sign off
- General client accounts – Bank statement, system generated bank balance, system generated individual client ledgers and list of reconciling items presented for review and sign off.
Unidentified Funds
- Unidentified funds are those receipts where the beneficiary is unknown or cannot be traced, preventing payment to or credit to the appropriate client.
- Any unidentified funds are investigated as soon as possible, and these funds remain client money.
- We list all unidentified funds and record actions taken to try and identify the client to which they relate.
- If it is not possible to identify what the money relates to, we will endeavour to return it to the sender.
- If funds held in any Client account are unidentified and we cannot trace to whom they belong, after three years we will donate those unidentified funds to a registered charity from whom a receipt and indemnity will be obtained.
Information provided to clients in respect of monies held on their account
- Our normal practice is to provide client money information to a client at a monthly or quarterly frequency, depending on the requirements agreed with the client.
- We confirm the bank operating conditions to clients in writing.
Hair & Son LLP
V18.03.2025