Introduction
- This is our approach to all articles.
- This document gives a guide and overview to:
- How we deal with Client’s Account and
- How we transact with the Client’s Money.
- This entire area is dealt with by the requirements laid down with by our regulatory body Institute of Chartered Accountants in England & Wales, Anti Money regulation and “Know your Client “KYC” practice, together with other legislation.
- Principally, it is dealt with in accordance with the instructions of and with the agreement of the Client. whether they be standing instruction, given at the outset or instructions given at that time.
- Such instructions may be given verbally (all telephone calls are recorded), confirmed via Telegram or given in writing.
- Avar has the sole discretion as to whether it choses to accept money from a source to be held for the benefit of the Client.
What is Client Money?
- Money of any currency which a firm holds or receives for or on behalf of a client.
- Not immediately payable on demand to the firm for its own account e.g. Fees.
- It must be held in the same currency in which it was received, unless the client instructs otherwise in writing.
What do I need to do before I can receive clients’ money?
- Verify identity of the client.
- Open a client bank account, which should have the client or clients in the title.
- Get confirmation from the bank that the account has a trust status.
- Appoint an alternative with authority to operate the account for the protection of the Client.
When should I open a separate designated clients’ bank account?
- If the firm expects to hold more than £10,000 for a client for more than 30 days.
- Firm cannot over-ride this requirement by getting the client’s consent to keep money in the general account.
How often do I need to reconcile my client accounts?
- At least every five weeks.
What if the bank has been charging the clients’ account with bank charges?
- Make good by transferring funds from the office account and instruct the bank to charge the office account in future.
- Such costs and interest belong to Client.
What to do if old balances can not be traced to the client?
- The firm could pay it to a registered charity, if the client has not been traced for five years.
- If the amounts are over £10,000 for each client, the registered charity should provide an indemnity against future claim by the client.
Is the flow of Client money insured?
- The monies are protected by the fact that all sole practitioners are required to have an alternate who is able to disburse the monies according to the clients wishes.
- An alternate is the suitably qualified individual or firm appointed by a sole principal (sole practitioner or sole director of a corporate practice) to continue the running of their practice in the event of their death or incapacity.
- Regulation 31 of the Clients’ Money regulations requires any sole practitioner who holds clients’ money to notify Institute of Chartered Accountants in England & Wales of their alternate arrangements.