CMP

Handling of Client Money

Scott Castle is a member of UKALA.

UKALA members must publish their client money handling procedures in their website, as well as

making copies available to customers upon request.

Scott Castle adheres to the Client Money Rules of Conduct, using the following procedures:

All Client Money is held in a ringfenced Client Money Account with HSBC, an authorised

bank.

Scott Castle operates Client Money Accounts into which all Client Money is paid

Scott Castle ensures that Client Money Accounts are designated as such and are easily

distinguished from any other account.

We have confirmed in writing with the bank holding the Client Money Account that the bank

acknowledges that the monies in the Client Money Account must not be combined with, or

transferred to, any other account maintained by the firm, and the bank shall not be entitled

to exercise any right of set off counterclaim against the money in the Client Money Account

in respect of any sum owed to it in respect of any other account of the firm.

Records and accounts are retained which show all dealings with client Money and

demonstrate that all Client Money held by the firm is held in a Client Money Account.

Scott Castle Publishes its procedures for handling Client Money on our website

Scott Castle provides copies of our procedures for handling Client Money to any person who

may reasonably require a copy, free of charge.

Records are retained which provide a history of all dealings with Client Money.

Client Money is repaid without delay if there is no longer any requirement to retain that

money.

Client money is repaid to the client upon request

Scott Castle holds appropriate Professional Indemnity insurance cover

General Controls

Scott Castle, its accounts team and Auditors ensure that;

Any employees with the client money contact will always have clear segregation of duties

and responsibilities.

An appropriately qualified individual oversees the client accounting function

Scott Castle employs competent and knowledgeable staff who are responsible for processing

clients’ money and are familiar with Client accounting rules

Scott Castle Accounting systems and client data are securely controlled and protected

Our IT and Computer systems are adequately protected for access, firewalls, back-ups, and

disaster recovery.

Scott Castle provides 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

Scott Castle holds client’s money in designated ring-fenced client accounts. Client money is available

on demand. The bank accounts are correctly titled to include the name of the firm and the word

“client” to distinguish the account from an office or any other account. This also includes accounts

where Scott Castle manage an estate or block. Written consent will be provided where interest has

been retained by the Agent.

Client Accounting Systems and Controls

Accounting records and systems are appropriate to the nature and volumes of the client

account transactions.

System provide details of all money received into and paid from all client accounts and show

running balance of all clients money held.

Systems identify all receipts and payments to the client to which they relate

Client ledgers show cash balances held on behalf of clients at all time

Accounting records are completed promptly

All ledgers include the Client name and reference

Overdrawn balances on client ledgers are prevented by system controls

Adequate controls are in place over unidentified client money to ensure that such funds are

kept securely.

A list of client bank account details will be maintained

Reconciliations take place on a regular basis.

Any transaction / payments received are logged the next working day to allow a full day

worth of transactions to ensure all payments are received.

Multiple / bulk payments made in and out of the accounts are logged, created with a unique

reference and a copy is saved separate from the system to allow tracking.

Any errors identified in the reconciliation process are promptly rectified.

Controls over the payment of Client Money

Scott Castle ensures that;

Checks are made to ensure that sufficient funds are held on behalf of the relevant client

before payments are made

Adequate authorisation procedures are in placed for payments made by electronic methods

All payments requests have supporting evidence and that documentation has been

authorised in advance by a Branch Manager

Effective controls are in place over the setting up of new supplier accounts on the system