Client Money Handling Procedure

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About this procedure

This document sets out how Limestone Residential Lettings handles money we hold for our clients. We publish it on our website and will give a copy, free of charge, to anyone who reasonably asks for one.

These procedures are designed to comply with the Client Money Protection Schemes for Property Agents (Approval and Designation of Schemes) Regulations 2018, any other relevant regulations and statutory requirements, and to follow best practice.

Definitions

Client

Any person, firm, trust, body corporate or other organisation that is a client of Limestone Residential Lettings.

Client money

Money of any currency (whether cash, cheque, draft or electronic transfer) that we hold or receive for or from a client, including money held as stakeholder, which is not immediately due and payable on demand to us for our own account. It includes fees paid in advance for professional work agreed to be carried out and clearly identifiable as such. Commissions and any other payment or advantage we have to account to the client for are also treated as client money.

Client money does not include tenancy deposits protected in a government-authorised tenancy deposit protection scheme.

Client money account

An account that holds only client money (in whole or in part), together with any sums needed to replace money withdrawn from the account in error, and any interest earned on those amounts.

The firm, we or us

Limestone Residential Lettings, a trading style of Lewis Christopher Limited, and any associated trading styles.

Client money protection

We are a member of the Propertymark Client Money Protection scheme. Our scheme reference number is C0129851. A copy of our client money protection certificate is available on request.

How we handle client money

• All client money is held in a client money account with a bank or building society authorised by the Prudential Regulation Authority (PRA) and regulated by the Financial Conduct Authority (FCA).
• We keep one or more client money accounts, into which all client money is paid. Each account is clearly designated as a client account and easily distinguished from our other accounts.
• We tell clients when their money will be held in a client money account and give them the details of that account.
• We have written confirmation from our bank that money in our client money accounts cannot be combined with, or transferred to, any other account we hold, and that the bank cannot use any right of set-off or counterclaim against that money for anything we owe it on another account.
• We keep records and accounts showing all dealings with client money, which demonstrate that all client money we hold is in a client money account.
• We repay client money, including any interest earned where feasible, without delay when there is no longer a need to keep it or when the client asks for it.
• We hold professional indemnity insurance that is appropriate to our size, income, type of work and the amount of client money we hold.
• If we hold surplus client money we can’t match to a client, we make every effort to trace the client or owner. We hold the money in a client suspense account for at least 6 years. After that, it will be donated to a registered charity and we’ll keep a receipt, which will be available to the rightful owner if they come forward. We will ask the charity for an indemnity so we can recover the donation if a valid claim is made.

General controls

• Staff have a clear separation of duties and responsibilities, and a principal or suitably qualified person oversees the client accounting function.
• Our staff are competent and knowledgeable.
• Accounting systems and client data are securely controlled and protected.
• Computer systems are properly protected, with access controls, firewalls, back-ups and disaster recovery.
• There is adequate cover for holidays and long-term absence.
• Principals cannot, and do not, override the controls around the accounting system.
• The same level of control applies across all areas of the business in relation to client accounting.

Client accounting systems and controls

• Our accounting records and systems are appropriate to the nature and volume of client account transactions. They record all money received into and paid out of every client account and show a running balance of client money held in each account.
• Every receipt and payment is linked to the client it relates to – for example, through client ledgers showing the balance held for each client at all times. Current balances at both total and client level are always available.
• Accounting records are completed promptly and in date order. Every ledger shows the client’s name and a suitable description, such as the property address.
• Our systems and controls prevent overdrawn client ledgers. If one does occur, it is investigated and put right immediately.
• We keep a central list of all client bank accounts, including the dates they were opened and closed.

Reconciliations

• Where client money is held in a general client account, we carry out a three-way reconciliation at least once a month. This is produced as a formal statement, and any unresolved differences or adjustments are fully investigated and explained. Any errors found are put right promptly.
• General client account reconciliations include a full list of client ledger balances and their total, dated unpresented cheques, dated outstanding deposits, details of any other reconciling items, and supporting system reports where appropriate.
• For designated (discrete) client accounts, monthly reconciliations agree the cash book or system balances and include the same supporting detail.
• Reconciliations should not include regularly recurring adjustments, or reconciling items more than 3 months old – except unpresented cheques, which should be no more than 6 months old.
• Reconciliations are reviewed and signed off by a principal or a suitably independent senior member of staff.
• Client accounting records, including copies of reconciliations, are kept securely for at least 6 years plus the current year.

Receiving client money

• Post is opened only by a principal or a suitable member of staff who is independent of the accounts team.
• All client money is banked within 3 working days.
• All cash and cheques received by post or by hand are recorded promptly, and money received by post is reconciled to that day’s banking.
• We have procedures to identify and separate client money from office money. Mixed payments are paid into a client account first, and the office element is moved to the office account once the payment has cleared.
• Fees received in advance for work not yet billed are held in a client account until the work is completed.
• Receipts are issued for cash received, cash is kept physically secure, and any unbanked client money is kept safe.

Making payments

• We check that enough money is held for the client before making any payment on their behalf.
• We hold an up-to-date copy of our bank mandate.
• Proper authorisation and supervision procedures are in place for payments made by cheque, bank transfer and other electronic methods. Where payments are made by staff who are not principals, adequate insurance and principal supervision are in place.
• Blank cheques are never signed, and unused cheques are kept securely.
• There are effective controls over setting up new supplier or payee details on our systems.
• We avoid making payments in cash.

If you have a concern

If you’re unhappy with how we’ve handled your money, please contact us using the details in our complaints procedure, which is available on our website or on request. Our complaints procedure also explains how to contact The Property Ombudsman and Propertymark.

Last updated: October 2026