Client Money Protection
Last updated 1st January 2026
1. Introduction and Policy Statement
At Prop247, we are committed to handling client money with the utmost integrity,
transparency, and security. This Client Money Protection (CMP) Policy outlines our
procedures for safeguarding funds held on behalf of landlords and tenants, ensuring
compliance with all legal and regulatory obligations.
Our primary goal is to provide peace of mind to our clients, knowing that their money –
including rent payments, tenancy deposits (before transfer to a scheme), and
maintenance funds – is protected against loss in the event of our insolvency or
misappropriation of funds.
2. Legal and Regulatory Framework
This policy is designed to ensure compliance with:
-
The Client Money Protection Schemes for Property Agents (Approval and
Designation of Schemes) Regulations 2019 (England): This legislation makes it
mandatory for all property agents handling client money in England to belong to a
government-approved CMP scheme. Similar regulations exist in Scotland and
Wales.
- The Housing and Planning Act 2016: This Act enabled the creation of the CMP
regulations.
- Terms and Conditions of our designated Client Money Protection Scheme.
- Relevant industry codes of practice and best practice guidelines.
- Compliance: Clearly states the primary legislation making CMP mandatory
3. Our Designated Client Money Protection Scheme
Prop247 is a proud member of Client Money Protect (CMP).
- Membership Certificate: Our CMP membership certificate is available via the
link on the prop247.co.uk website. Membership number is CMP014480.
- Protection Limit: This scheme provides protection for client money up to a
maximum of £99,999 per client.
- Claiming Against the Scheme: In the unlikely event of our insolvency or
misappropriation of client funds, clients can make a claim directly to Client
Money Protect in accordance with their scheme rules. Details on how to claim will
be provided by the scheme.
- Compliance: Mandatory to be a member of an approved scheme. Transparency
requirements include displaying the certificate and clearly stating the scheme
name, protection limit, and how to claim
4. Definition of Client Money
For the purposes of this policy, "Client Money" includes (but is not limited to):
- Rent collected from tenants on behalf of landlords.
- Tenancy deposits received from tenants (prior to transfer to a Tenancy Deposit
Scheme). - Funds held for property maintenance and repairs on behalf of landlords.
- Application fees or holding deposits (if applicable and held before conversion to
tenancy deposit/rent).
- Any other money received from or on behalf of clients (landlords, tenants, third
parties) in connection with property management or letting services.
- Best Practice: Clearly defining "client money" prevents ambiguity.
5. Client Money Handling Procedures
We operate strict procedures to ensure client money is handled securely and
transparently:
5.1. Segregated Client Money Bank Account
- All client money received by MyProperty247 Limited is paid into a designated,
segregated client money bank account at a regulated bank, (Barclays Bank).
- This account is clearly identified as a "Client Money Account" and is separate from
our company's operational/office bank accounts.
- Funds in this account are held in trust for our clients and cannot be used for the
company's own expenses or liabilities.
- Compliance: A fundamental requirement of CMP schemes and financial best
practice. Segregation prevents commingling of client and business funds.
5.2. Client Money Receipt and Recording
-
All client money received, whether by bank transfer, card payment, or cheque, is
promptly banked into the client money account, typically within 2 working days of
receipt.
-
Detailed records are maintained for all client money received, including:
-
Date of receipt.
- Amount received.
- Name of payer.
- Purpose of payment (e.g., rent, deposit, maintenance).
- Property address it relates to.
- Best Practice: Prompt banking and detailed record-keeping are crucial for
accuracy and auditability.
5.3. Client Money Payments (Disbursements)
-
Payments from the client money account (e.g., rent remittances to landlords,
contractor payments for repairs, deposit transfers) are made only with proper
authorisation and supporting documentation.
- Payments are typically made by secure electronic bank transfer. Cash payments
are avoided wherever possible.
- Detailed records are maintained for all client money payments, including
-
Date of payment.
- Amount paid.
- Name of payee.
- Purpose of payment.
- Property address it relates to.
- Best Practice: Strong internal controls over payments minimise risk.
5.4. Bank Reconciliations
-
We perform regular, formal reconciliations of our client money bank account.
- This involves reconciling the balance shown on our client money ledger with the
balance on the bank statement, and ensuring that all transactions are correctly
allocated and accounted for
- These reconciliations are performed at least monthly and are reviewed by a senior
member of staff not involved in the day-to-day processing
- Any discrepancies are investigated and resolved immediately.
-
Compliance: Mandatory requirement of all CMP schemes. Regular, robust
reconciliations are the primary control for detecting errors or
misappropriation.
5.5. Client Money Accounting Records
-
We maintain comprehensive, accurate, and up-to-date accounting records for all
client money
- Our accounting system clearly differentiates between individual client balances
and the overall client money held
- Records are kept in a format that allows for easy retrieval and audit
- Compliance: A key aspect of demonstrating accountability.
5.6. Tenancy Deposit Protection (TDP)
-
While tenancy deposits are client money, they have specific regulations under the
Housing Act 2004.
- All eligible tenancy deposits received are transferred to a government-approved
Tenancy Deposit Scheme (TDS) within 30 calendar days of receipt.
- The Prescribed Information relating to the deposit is issued to the tenant within
the same 30-day period
- Compliance: A separate but related legal obligation. Funds held prior to
transfer to the TDP scheme are still protected by CMP.
6. Internal Controls and Audit
-
Segregation of Duties: Responsibilities for handling money, recording
transactions, and performing reconciliations are separated among different
members of staff to prevent fraud and error.
- Authorisation Limits: Clear authorisation procedures are in place for all client
money payments.
- Regular Internal Audits: Periodic internal checks are conducted to ensure
compliance with this policy.
- External Audit/Certification: As part of our CMP scheme membership, our client
money handling procedures and accounts are subject to annual external audit
and certification by a qualified accountant. This provides an independent
assurance of our compliance.
-
- Compliance: External audit/certification is a mandatory CMP scheme
requirement. Strong internal controls are best practice.
7. Staff Training and Awareness
-
All staff involved in handling client money receive comprehensive training on this
CMP Policy, associated procedures, and their responsibilities.
- Training covers identifying potential risks, internal reporting mechanisms, and the
importance of adhering to the strict controls.
- Training is provided during induction for new staff and regularly
updated/refreshed for all relevant personnel.
-
Best Practice: Essential for effective implementation and risk mitigation
8. Reporting Breaches
- Any suspected or actual breach of this Client Money Protection Policy, including
any loss, misuse, or misappropriation of client funds, must be reported
immediately to [Senior Manager/Director Name/Role, or the MLRO if also an AML
concern].
-
Serious breaches, especially those involving a loss of client money, will be
reported to our CMP scheme and, where applicable, to HMRC or the police, in
accordance with our legal obligations and CMP scheme rules.
-
Best Practice: Clear internal reporting lines for breaches
9. Policy review
This Client Money Protection Policy will be reviewed at least annually, and updated
whenever there are:
-
Changes in relevant legislation or regulations.
- Changes in our CMP scheme's rules.
- Significant changes to our business operations or accounting systems.
- Any identified weaknesses in our procedures
10. Contact information
If you have any questions regarding our Client Money Protection Policy, please contact:
Irvine Conner
Prop 247
Email: [email protected] and use Subject: CMP
For information on making a claim against our CMP scheme, please refer directly to their
website:
Scheme Name: Client Money Protect
Website: Client Money Protect