The purpose of this policy is to set out the minimum controls required for the receipt, holding, recording, safeguarding, reconciliation, transfer and reporting of client money by Savills Northern Ireland. The policy is intended to ensure that client money is protected, clearly identifiable, properly recorded, segregated from company funds, and handled in accordance with applicable legal, regulatory, contractual and professional obligations.

For the purposes of this policy, “client money” includes money held or received by Savills Northern Ireland on behalf of a client or other third-party in connection with the provision of property services, including but not limited to rents, service charges, sinking fund contributions, deposits, booking deposits, security deposits, insurance proceeds, sale-related monies, or other funds held for onward payment or administration. 

This policy supplements and should be read in conjunction with the other Savills policies and procedures in force from time to time.

This policy applies to all Savills Northern Ireland employees, contractors and temporary staff who receive, hold, process, record, authorise, transfer, reconcile or report on client money in connection with the provision of property services.

For the purposes of this policy, “client money” includes (without limitation) rents, service charges, sinking fund contributions, deposits (including booking and security deposits), insurance proceeds, sale-related monies, and any other funds held for onward payment or administration.

This policy applies to client money held in:

a) Designated client/property specific client bank accounts;

b) Designated grouped client bank accounts; and

c) Client-controlled bank accounts where Savills Northern Ireland has viewing and/or payment approval access.

This policy does not apply to:

• Savills Northern Ireland operating/company funds; and
• client money held entirely by third parties where Savills Northern Ireland has no access and does not maintain accounting records (unless otherwise agreed contractually).

Where local legal/regulatory requirements (e.g. PSRA in ROI or other applicable obligations) impose stricter controls than this policy, the stricter requirement applies.

Client money relates to money of any currency, whether in the form of cash, cheque or electronic transfer, which is:

a)held or received on behalf of another person, including money held by a regulated firm as a stakeholder.

b)is not immediately due and payable on demand.

As part of the Royal Institute of Chartered Surveyors (RICS) professional statement (Client money handling, effective from 1st January 2020), and internal due diligence, client money held or received by Savills Ireland Ltd (Savills) is either banked into a designated client account or held in a client-controlled bank account.

The type of bank account being allocated or used for each client depends on their individual requirements and the Savills finance team discuss this at the onboarding stage with the client and agree and arrange for the required banking structure to be implemented. This agreed structure is documented in line with our ISAE 3402 audit requirements.

A designated client / property specific bank account is a client / property-named bank account which holds client money. All landlord and tenant monies are kept separate and further details of where funds are held, including the allocation of designated accounts, can be found within the PMA.

A designated grouped client bank account is a Savills client-named bank account which holds multiple client / property money belonging to our clients. All landlord and tenant monies are kept separate.

A client-controlled bank account is a bank account(s) which the client has set up specifically for their asset and is controlled and managed by the client. Savills are generally granted viewing access to this bank account(s) and depending on client requirements may be provided with payment approval access. A list of users with access to client bank accounts is maintained by the PM Compliance team.

Client money is held in an appropriate banking institution and regulated by the Central Bank of Ireland (ROI) or the Financial Conduct Authority (NI).

Account listings are maintained by PM Compliance and reviewed by Head of Property Management and Head of Property Management Finance on a 6-months basis.

Closure of designated client bank accounts is processed by the Client Accountant and forms are prepared by the PM Compliance team for signing by the statutory directors in line with banking providers processes.

PM Mandate signatories are restricted to any two of the following individuals:

Copies of the full mandates are held by the Property Management Compliance team. These bank accounts are segregated from other Savills NI bank accounts and are managed and monitored by the Property Management Compliance team. PM Online bank approval users are restricted to any two of the following:

User Access is maintained by Property Management Compliance and reviewed by Head of Property Management and Head of Property Management Finance on a 6-months basis. A user can only be added to the signature mandate by board approval which must be signed-off by the statutory directors.

A withdrawal from a client account can only be made after a specific authority has been approved by a signatory/ approver in accordance with the bank mandate.

All payment requests must be processed through a system workflow in accordance with the applicable flow they relate to (E.g. Payment to Client request, Deposit refund request etc.,) this ensures that there is appropriate segregation of duties which is documented for review by the departments ISAE 3402 auditor to ensure this function is in place to prevent data tampering within the payment process. The request includes confirmation by the PM Bank approval users that the payment has been checked and authorised in accordance with the segregation of duties in the client accounting function.

Interest

It is Savills policy to not hold client funds in an interest-bearing account due to the administrative burden it would place on the finance department to manage, process and maintain the required reports to account for the interest earned.

Sinking funds held for commercial and block management properties are held in interest bearing (client / property specific and grouped client accounts) deposit accounts and the aggregate of the interest earned is allocated to the percentage of each properties sinking fund balance compared to the overall balance held in the deposit account over the period.

Bank Charges

Bank charges are paid out of a centrally held Savills finance bank account, Savills on an annual basis invoice the properties a bank administration fee to cover the cost of these charges.

Daily MT940 bank statements are reviewed by the Credit Control team with statements being reconciled/ closed once transactions are matched. Controls are in place to check previous day’s opening balance on the MT940 statement to the closing balance on the system from the previous day.

The monthly bank reconciliation review commences on the 5th working day after month-end with the bank balance and the system GL balance being automatically uploaded to the system. If there is no difference between the bank balance and the system GL balance the record is auto reconciled with no additional reconciliation required by the Credit Control team. Where there is a difference between these two amounts the Credit Control team must prepare the bank reconciliation, attach the relevant back up and document the reconciling items including the close date of the item.

Once the Credit Control team completes their steps (noted above), the reconciliation moves to the Client Accountant team to review before the record can be marked as completed.

For each client bank account, a monthly reconciliation must include:

a) bank statement balance;

b) cashbook/system GL balance; and

c) the total of the client ledger balances (or equivalent sub-ledger).

Reconciliations must be reviewed, signed-off and dated by an independent senior reviewer (not the preparer), with evidence retained.

Controls must be in place to prevent individual client ledgers becoming overdrawn. Any overdrawn client ledger balance or client bank account shortfall must be immediately escalated to Head of Property Management Finance, investigated, corrected, and documented (including root cause and corrective actions).

The completion of the monthly bank reconciliations is due by the 10th working day following month end.

A bank reconciliation overview report is run monthly and monitored by the Senior Management Group and discussed at their monthly meeting.

On an annual basis property management bank accounts are subject to external ISAE 3402 audit, additionally relevant accounts are subject to external Property Services Regulatory Authority (PSRA) audit for the periods of June and December each year.

8.1. REPORTING

Reporting and frequency requirements are agreed and documented with the client and provided in line with the agreement.

8.2. UNIDENTIFIED FUNDS (CLIENT SUSPENSE)

Unidentified funds are receipts where the payer and/or intended client/property allocation cannot be determined at the time of receipt.

• Immediate recording: Unidentified funds must be recorded in a designated suspense/client suspense ledger and must not be treated as Savills Northern Ireland funds.
• Investigation and trace: The Finance Team/Credit Control will promptly investigate to identify the correct client/property allocation, including review of remittance advice, bank narrative, internal system references, and contacting the payer where appropriate.
• Escalation: Where funds remain unidentified after reasonable steps, the matter must be escalated to Head of Property Management Finance with an investigation log retained.
• Holding period: Unidentified funds must be reviewed at least monthly as part of reconciliation and held for at least three (3) years from the date of receipt.
• Charity donation: If, after at least three (3) years, the funds remain unidentified/unclaimed, the funds must be donated to a registered charity. A receipt must be obtained and retained. The receiving charity should provide Savills Northern Ireland with an indemnity in respect of any later claim by the rightful owner.
• Documentation: The final disposition decision and supporting evidence (approvals, charity details, receipt, indemnity) must be retained and be available for audit.

Employees must report any breach of this policy (this includes their own breach or that of another employee) immediately to Finance and Compliance. Incidents must be logged, investigated, remediated and reviewed for root cause. Corrective actions must be documented and tracked to completion.

This policy is reviewed at least annually (or sooner where regulatory/professional requirements change, or where monitoring/audit findings indicate a need to strengthen controls). The Finance Team is responsible for maintaining the policy, coordinating updates with Property Management Finance and relevant business leads, and ensuring the current version is available on Connect.