London & Country

Handling of Client Money

All Client Money is held in a Client Money Account with an authorised bank or building society
We maintain one or more Client Money Account(s) into which all Client Money is paid
We ensure that Client Money Account(s) are designated as such and are easily distinguished from other accounts
We have written confirmation from the Banks that they acknowledge that monies in the client account must not be combined with, or transferred to, any other account maintained by the company. The said banks shall not be entitled to exercise any right to set off or counterclaim against the money in that Client Money Account in respect of any sum owed to it in respect of any other account held by the company
We keep records and accounts that show all dealings with Client Money and demonstrate that all Client Money held by the Company is held in a Client Money Account
Our policy and procedures for handling client money are published on our website
We provide a copy of our procedures for handling Client Money to any person who may reasonably require a copy, free of charge
We keep records and accounts that show all dealings with Client Mone
We repay any Client Money without delay if there is no longer any requirement to retain that money or the relevant client requests it
We will ensure that there are always sufficient funds in the client accounts to pay amounts owing to clients, as they fall due under the terms of business, as agreed and signed with the client
We hold and maintain Professional Indemnity insurance cover that is appropriate for the Company’s size, income, type of work and the amount of Client Money held, in accordance to our Client Money Protection scheme membership (UKALA)

General compliance

Employees have clear segregation of duties and responsibilities and that a Principal, or appropriately qualified individual oversees the client accounting function
Principals cannot and do not override controls surrounding the accounting system
Competent and knowledgeable staff are employed who are responsible for processing clients’ money and who are familiar with Client Accounting rules
Our accounting procedures, systems and data are securely controlled and protected for access, backups, firewalls and disaster recovery
There is adequate cover for holiday and long-term absence
All areas of the business apply the same level of controls in relation to the client accounting function

Client Bank Accounts

We hold clients’ money in one or more client bank accounts separate from all other monies
Client money is available on demand
The bank account is correctly titled to include the name of the Company and the word “client” to distinguish the account from an office or any other account
We keep records and accounts which show all dealings with Client Money
We can demonstrate that all Client Money held by the company is held in a Client Money Account
We maintain details and records for all dealings with client money to ensure clarity, accuracy and completeness
We have obtained written consent if the Company is to retain interest

Client Accounting Systems and Controls

Accounting records and systems are appropriate to the nature and volumes of client account transactions
Systems provide details of all money received into and paid from all client accounts and show a running balance of all client money held in that account
Systems identify all receipts and payments to the client to which they relate; for example, by means of client ledgers showing cash balances held on behalf of clients at all times
Accounting records are completed chronologically and promptly
The current balances at the total and client levels are always available
All client ledgers are clearly named with the client’s name and 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 client should be located and reimbursed as soon as possible. Such funds held for more than six years may be donated to a registered charity
Client accounting records, including copies of reconciliations, are securely kept for at least six years plus the current year

Controls over receipt and payment of Client Money

Our software systems identify all receipts and payments relating to the client accounts
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
Fees received in advance for professional work not yet billed are paid into a client account pending completion of the work
Cash payments are discouraged, are rarely accepted only under extenuating circumstances
Procedures exist to ensure all clients’ money is banked within three working days
Duplicate receipts are issued for cash received and controls over the physical security of cash are effective.
Checks are made to ensure that sufficient funds are held on behalf of the relevant client before payments are made
Adequate authorisation and supervision procedures are in place for payments made by cheque, 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
There is no cheque book for the client account

Client Money Handling

London and Country Limited Client Money Handling Procedures

Handling of Client Money

General compliance

Client Bank Accounts

Client Accounting Systems and Controls

Controls over receipt and payment of Client Money

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