1.    All Client Money is held in a Client Money Account with an authorised bank;

2.    We maintain one or more Client Money Account(s) into which all Client Money is paid;

3.    We ensure that Client Money Account(s) are designated as such and are easily distinguished from other accounts;
4.    We have confirmed in writing with the bank holding the Client Money Account that the bank acknowledges that monies in the Client Money Account must not be combined with, or transferred to, any other account maintained by the Company, and the bank shall not be entitled to exercise any right of set off or counterclaim against the money in that Client Money Account in respect of any sum owed to it in respect of any other account of the Company;
5.    We keep records and accounts that show all dealings with Client Money and demonstrate that all Client Money held by the Company is held in a Client Money Account;
6.    We publish our procedures for handling Client Money on our website;
7.    We provide a copy of our procedures for handling Client Money to any person who may reasonably require a copy, free of charge;
8.    We keep records and accounts that show all dealings with Client Money;
9.    We repay any Client Money without delay if there is no longer any requirement to retain that money or the relevant client requests it; and
10.    We hold and maintain Professional Indemnity insurance cover that is appropriate for the Company’s size, income, type of work and the amount of Client Money held.

GENERAL CONTROLS

Broad Oak, it’s Accounts team and Auditors ensure that:
Any employees with client money contact have a clear segregation of duties and responsibilities and that an appropriately qualified individual oversees the client accounting function.

Broad Oak employs competent and knowledgeable staff who are responsible for processing clients’ money and are familiar with Client Accounting rules

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.
There is adequate cover for holiday and long-term absence

Principals cannot and do not override controls surrounding the accounting system

All areas of the business apply the same level of controls in relation to the Client Accounting Function.

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CLIENT ACCOUNTING SYSTEMS AND CONTROLS
Accounting records and systems are appropriate to the nature and volumes of client account transactions.

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

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

Current balances and period reports are available upon demand. 

Accounting records are completed promptly. 

Overdrawn balances on client ledgers are prevented by system controls.

A list of client bank accounts is maintained.

Daily reconciliations are performed.

Further reconciliations are completed at least once every month where clients’ money is held in a general client account. 

Any unresolved differences are fully investigated and explained.

Any errors identified in the reconciliation process are promptly rectified.

General Client Account reconciliations should include a full list of client ledger balances and the total of the balances; dated unpresented cheques; dated outstanding deposits; details of any other reconciling items; system reports supporting reconciliation figures as appropriate.

For discrete accounts the monthly reconciliations should agree the cash book or system balances and include a full list of dated unpresented cheques; dated outstanding deposits; details of any other reconciling items; system reports supporting reconciliation figures as appropriate.

Client accounting records, including copies of reconciliations are securely kept for at least six years plus the current year.

An independent auditor signs off the accounts annually.

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CONTROLS OVER THE RECEIPT OF CLIENT MONEY
Broad Oak ensures that:
All cash and cheques received by post or by hand are promptly recorded.

Adequate authorisation procedures are in place for payments made by electronic methods. 

 

CONTROLS OVER THE PAYMENT OF MONEY
Checks are made to ensure that sufficient funds are held on behalf of the client before payments are made. 

All payment requests have supporting evidence and that has been authorised in advance by a manager.

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

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CLIENT MONEY ACCOUNT DETAILS
Client Money Protect membership number CMP002711