Client money is held in general and discrete client accounts that are completely separate from the firm’s operational and business accounts.
The client accounts are maintained at a UK-authorised bank that is regulated by the Financial Conduct Authority (FCA).
The account name includes the term ‘client account’ to distinguish it from other business accounts.
Client money is only used for the purpose for which it was received and is never mixed with the company’s own funds.
Client money accounts are either ‘General’ (clients funds are pooled together) or ‘Discrete’ (the account name quotes the client name and only has funds for that client).
Access to client money is strictly limited to designated individuals within Paton & Co Group LLP.
Only Senior Associates or Partner of Paton & Co Group LLP may approve or make payments from client accounts.
Authorised personnel are reviewed regularly to ensure only appropriate individuals have access to client funds.
Internal controls are in place to prevent unauthorised access, including password-protected banking systems and dual authentication requirements.
All client money received is deposited into the client account without undue delay and usually within 3 days of receipt.
All cheques are logged on a Cheque Register, which is reviewed monthly.
Payments from a client account can only be made for legitimate purposes and in accordance with the client’s instructions or contractual obligations.
All payments require authorisation from a Paton & Co Partner.
Payments are reviewed to ensure they align with the relevant client ledger and supporting documentation.
No payments are made that would result in a client account being overdrawn.
Interest received on general accounts is retained by Paton & Co Group LLP to cover banking charges and administration costs unless separately agreed with the client.
Interest received on discrete client accounts is retained by the client.
Any bank charges incurred on the general and discrete client accounts are paid by Paton & Co.
Client accounts are reconciled at least once every month to ensure accuracy and compliance with regulatory standards.
Reconciliations include a full review of client money held, payments made, and any outstanding balances.
Any discrepancies identified in the reconciliation process are investigated immediately and rectified as required.
We take prompt action to identify any unidentified receipts into client accounts. If funds are unidentified for a period greater than 3 years.
Records of reconciliations are maintained for auditing and regulatory purposes.
A Paton & Co Accounts Partner reviews and signs off reconciliations to ensure compliance.
Clients can request regular statements detailing the balance of their account and any transactions carried out on their behalf.
Statements include details of all funds received, payments made, interest applied (if applicable), and any deductions.
Clients are notified promptly of any significant transactions that affect their account balance.
For further information or concerns regarding client money, please contact:
Mrs Teresa Leith
Paton & Co Group LLP
New Elgin Road
Moray
IV30 6BA
Email: [email protected]
Phone: 01343 862 969
This procedure is reviewed annually to ensure compliance with RICS regulations and best practices. Updated procedures will be published on our website.

© Paton & Co, Scottish Borders, Berwick, Moray, Highlands; covering Scotland & Northumberland
Paton & Co Group LLP Registered in Scotland Partnership No. SO303880
Letting Registration Number LARN 1807018
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