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Client Funds Management

For Solicitors

Client Funds Management

Indemnity, Compliance and Notification Provisions

E-Solicitors Legal Services Marketplace

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Mandatory Client Money Compliance

Client Accounts | SRA Accounts Rules | COFA | Safeguarding

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Version 2.0 - January 2026

England and Wales

Important Notice to Solicitors

  • YOU INDEMNIFY THE PLATFORM FOR ALL MATTERS RELATING TO YOUR MANAGEMENT OF CLIENT FUNDS. YOU MUST NOTIFY THE PLATFORM OF ANY BREACH OF CLIENT MONEY RULES.

Client Money is Sacrosanct

The protection of client money is one of the most fundamental obligations of a solicitor. Breaches of client money rules are among the most serious regulatory failures and can result in intervention, striking off, and criminal prosecution.

Platform's Position

The Platform:

Does NOT hold, receive, or process client money

Does NOT operate client accounts

Does NOT have any role in your client money arrangements

Is NOT responsible for your SRA Accounts Rules compliance

Is NOT your COFA or responsible for your financial compliance

Your Indemnity Obligations

🛡 INDEMNITY: You indemnify the Platform for ALL claims arising from your client money handling

🛡 INDEMNITY: You indemnify the Platform for SRA Accounts Rules breaches

🛡 INDEMNITY: You indemnify the Platform for client fund losses or shortfalls

🛡 INDEMNITY: You indemnify the Platform for regulatory action relating to client money

🛡 INDEMNITY: You indemnify the Platform for Compensation Fund claims

Notification Requirements

🔔 NOTIFY PLATFORM: You must notify the Platform IMMEDIATELY of any material breach of client money rules

🔔 NOTIFY PLATFORM: You must notify the Platform of any SRA investigation into client money

🔔 NOTIFY PLATFORM: You must notify the Platform of any client money shortfall

🔔 NOTIFY PLATFORM: You must notify the Platform of any intervention or conditions relating to client money

  • Failure to notify may itself be a breach of these Terms and trigger additional indemnity obligations.

Contents

Part A: General Provisions

  1. Definitions

  2. Platform Status

  3. Your Status and Obligations

  4. Scope of This Agreement

Part B: Sra Accounts Rules Compliance

  1. SRA Accounts Rules 2019

  2. Client Money Definition

  3. Client Account Requirements

  4. Keeping Client Money Separate

  5. Client Money Receipts and Payments

  6. Interest on Client Money

Part C: Governance and Oversight

  1. COFA Requirements

  2. Accounting Systems and Controls

  3. Reconciliations

  4. Accountant's Reports

  5. Record Keeping

Part D: Third Party Managed Accounts

  1. TPMA Arrangements

  2. TPMA Requirements

Part E: Freelance Solicitors

  1. Client Money Restrictions

  2. Alternative Arrangements

Part F: Aml and Client Money

  1. Source of Funds Verification

  2. Suspicious Transactions

  3. Third Party Payments

Part G: Fca Requirements

  1. When FCA Applies

  2. Client Assets Rules

Part H: Breach Notification

  1. Immediate Notification Events

  2. Prompt Notification Events

  3. Notification Procedure

  4. Ongoing Reporting

Part I: Indemnity Provisions

  1. General Client Money Indemnity

  2. Indemnity for SRA Breaches

  3. Indemnity for Client Losses

  4. Indemnity for Regulatory Action

  5. Indemnity for Third Party Claims

  6. Scope and Survival

Part J: Platform Remedies

  1. Suspension

  2. Termination

  3. Reporting to Regulators

Part K: General Provisions

  1. Warranties

  2. Insurance

  3. Governing Law

Schedules

Schedule 1: Client Money Compliance Declaration

Schedule 2: Breach Notification Form

Schedule 3: Client Money Compliance Checklist

Schedule 4: COFA Confirmation

Schedule 5: Indemnity Acknowledgment

Part A: General Provisions

  1. Definitions

1.1 In this Agreement:

'Accountant's Report' means the report required under SRA Accounts Rules Rule 12.

'Authorised Body' means a body authorised by the SRA to provide legal services.

'Claim' means any claim, action, proceeding, demand, liability, loss, damage, cost, or expense.

'Client Account' means an account at a bank or building society in the name of the firm and designated as a client account.

'Client Money' means money held or received for a client or as trustee, excluding money held or received for payment of your own fees or disbursements already incurred.

'COFA' means Compliance Officer for Finance and Administration.

'Compensation Fund' means the SRA Compensation Fund.

'Indemnified Parties' means the Platform, its parent companies, subsidiaries, affiliates, directors, officers, employees, and agents.

'Intervention' means intervention by the SRA into your practice.

'Losses' means all losses, liabilities, damages, costs, expenses (including legal fees), fines, penalties, and other amounts.

'Office Account' means an account for your own money, not client money.

'Platform' means [Platform Name], operated by [Company Name].

'SRA Accounts Rules' means the SRA Accounts Rules 2019 (as amended).

'Third Party Managed Account' or 'TPMA' means an account held by a third party in which client money may be held in accordance with SRA Rules.

'You/Your' means the solicitor or authorised body accepting these Terms.

  1. Platform Status

2.1 The Platform:

(a) Is a technology marketplace facilitating

introductions;

(b) Does NOT hold, receive, or process Client

Money;

(c) Does NOT operate Client

Accounts;

(d) Does NOT receive payments intended for client

accounts;

(e) Is NOT regulated by the

SRA;

(f) Has NO role in your client money

arrangements;

(g) Is NOT responsible for your SRA Accounts Rules

compliance;

(h) Is NOT your COFA or involved in your financial compliance.

2.2 All Platform fees are payable to the Platform's own accounts and are NOT Client Money.

  1. Your Status and Obligations

3.1 You are solely responsible for:

(a) Compliance with SRA Accounts

Rules;

(b) Proper handling of all Client

Money;

(c) Maintaining compliant Client

Accounts;

(d) COFA appointment and oversight (if applicable

);

(e) Obtaining Accountant's

Reports;

(f) All record keeping for client

money;

(g) Reporting breaches to the

SRA;

(h) Notifying the Platform of relevant breaches.

  1. Scope of This Agreement

4.1 This Agreement covers:

(a) Your compliance obligations regarding Client

Money;

(b) Your notification obligations to the

Platform;

(c) Your indemnity obligations to the

Platform;

(d) Platform remedies for breaches.

Part B: Sra Accounts Rules Compliance

⚖ LEGAL REQUIREMENT: The SRA Accounts Rules 2019 govern how solicitors must handle Client Money. Breach is a serious regulatory matter.

  1. SRA Accounts Rules 2019

5.1 You warrant that you comply with all SRA Accounts Rules, including:

Rule

Requirement

Key Obligations

Rule 2

Client money must be kept safe

Safeguard all client money

Rule 2.1

Keep client money separate

Never mix with your own money

Rule 2.2

Identify client money promptly

Identify receipt of client money

Rule 2.3

Pay into client account promptly

No undue delay in banking

Rule 2.4

Withdraw only when permitted

Only for proper purposes

Rule 2.5

Properly account to clients

Accurate client ledgers

Rule 3

Client accounts requirements

Use authorised banks

Rule 4

Client money receipts

Proper handling procedures

Rule 5

Client money withdrawals

Authorisation and records

Rule 7

Client accounting records

Proper records maintained

Rule 8

Reconciliations

Monthly reconciliations

Rule 12

Accountant's reports

Annual reporting requirements

  1. Client Money Definition

6.1 Client Money includes:

(a) Money held on behalf of

clients;

(b) Money held as

trustee;

(c) Payments on account of costs before bills

delivered;

(d) Money held for disbursements not yet

paid;

(e) Money held for third parties in connection with client matters.

6.2 Client Money does NOT include:

(a) Money paid for fees already

billed;

(b) Money for disbursements already

incurred;

(c) Money agreed to be held in your office account.

  1. Client Account Requirements

7.1 You warrant that your Client Account(s):

(a) Are held at an authorised UK bank or building

society;

(b) Are designated as a 'client account

';

(c) Are in the name of the firm or authorised

body;

(d) Are not used for any other

purpose;

(e) Are properly authorised and

controlled;

(f) Are protected from your own creditors.

7.2 You must maintain:

(a) Adequate client account

capacity;

(b) Proper bank mandates and

authorities;

(c) Appropriate signatories and

controls;

(d) Separation from office account(s).

  1. Keeping Client Money Separate

8.1 You warrant that

you

Never:

(a) Use client money for your own

purposes;

(b) Mix client money with your own

money;

(c) 'Borrow' from client

account;

(d) Use one client's money for

another;

(e) Pay personal expenses from client

account;

(f) Treat client money as available to you.

  • Using client money for your own purposes is theft and may result in criminal prosecution, intervention, and striking off.
  1. Client Money Receipts and Payments

9.1 For receipts, you must:

(a) Identify client money promptly on

receipt;

(b) Pay into client account without

delay;

(c) Ensure payment into correct client

ledger;

(d) Obtain and retain evidence of receipt.

9.2 For payments, you must:

(a) Only withdraw for permitted

purposes;

(b) Ensure sufficient funds in client

ledger;

(c) Properly authorise all

withdrawals;

(d) Maintain audit trail for all payments.

  1. Interest on Client Money

10.1 Under SRA Accounts Rules Rule 2.2:

(a) You must account to clients for interest (where fair and reasonable

);

(b) You must have a policy on payment of

interest;

(c) The policy must be fair to

clients;

(d) You must inform clients of the policy.

Part C: Governance and Oversight

  1. COFA Requirements

11.1 If you are an Authorised Body, you must have a COFA who:

(a) Is approved by the

SRA;

(b) Has appropriate seniority and

authority;

(c) Has access to all relevant

information;

(d) Reports to management on

compliance;

(e) Is responsible for SRA Accounts Rules

compliance;

(f) Has sufficient resources and time.

11.2 COFA responsibilities include:

(a) Ensuring compliance with SRA Accounts

Rules;

(b) Ensuring adequate accounting

systems;

(c) Monitoring

reconciliations;

(d) Reporting breaches to the

SRA;

(e) Oversight of Accountant's Reports.

11.3 If you are a sole practitioner or freelance solicitor, you bear COFA responsibilities personally.

  1. Accounting Systems and Controls

12.1 You must maintain:

(a) Proper accounting systems for client

money;

(b) Accurate client ledgers for each

client;

(c) Clear separation of client and office

accounts;

(d) Adequate internal

controls;

(e) Authorisation procedures for

payments;

(f) Audit trails for all transactions.

12.2 Systems must:

(a) Be appropriate for your size and

complexity;

(b) Allow identification of all client money at any

time;

(c) Enable reconciliations to be

performed;

(d) Support preparation of Accountant's Reports.

  1. Reconciliations

13.1 Under SRA Accounts Rules Rule 8, you must:

(a) Reconcile client account at least every 5

weeks;

(b) Compare client account balance to client ledger

balances;

(c) Identify and resolve all differences

promptly;

(d) Maintain records of

reconciliations;

(e) Report material discrepancies.

13.2 Reconciliation must show:

(a) Balance per bank

statement;

(b) Unpresented cheques and

lodgements;

(c) Adjusted bank

balance;

(d) Total of client ledger

balances;

(e) Any difference and explanation.

  1. Accountant's Reports

14.1 Under SRA Accounts Rules Rule 12:

(a) You must obtain an Accountant's Report if you hold client

money;

(b) Report must be prepared by a qualified reporting

accountant;

(c) Report period is normally 12

months;

(d) Report must be delivered to SRA within 6 months of period

end;

(e) Report must identify any breaches.

14.2 You warrant that:

(a) You obtain Accountant's Reports as

required;

(b) You cooperate fully with reporting

accountants;

(c) You address any issues raised in

reports;

(d) You report qualified opinions to the

SRA;

(e) You notify the Platform of material issues.

  1. Record Keeping

15.1 You must maintain records of:

(a) All client account

transactions;

(b) Individual client

ledgers;

(c) Client account

reconciliations;

(d) Bank statements and

vouchers;

(e) Authorisations and

approvals;

(f) Accountant's Reports.

15.2 Records must be:

(a) Retained for at least 6

years;

(b) Readily

accessible;

(c) Available to SRA on

request;

(d) Available to reporting accountants.

Part D: Third Party Managed Accounts

  1. TPMA Arrangements

16.1 If you use a

Third Party

Managed Account:

(a) The TPMA must comply with SRA

requirements;

(b) You remain responsible for client money

protection;

(c) Client money in TPMA is still client

money;

(d) You must have a written agreement with the TPMA

provider;

(e) You must notify clients of TPMA arrangements.

  1. TPMA Requirements

17.1 The TPMA arrangement must ensure:

(a) Client money is

ring-fenced;

(b) Client money is protected from provider

insolvency;

(c) You can identify amounts held for each

client;

(d) Clients are informed of the

arrangements;

(e) You can comply with all SRA

requirements;

(f) SRA and reporting accountants have appropriate access.

Part E: Freelance Solicitors

  1. Client Money Restrictions

18.1 If you are a Freelance Solicitor:

(a) You CANNOT hold client

money;

(b) You CANNOT maintain a client

account;

(c) You CANNOT receive client

money;

(d) All client payments must go to the instructing entity or client.

  • Freelance Solicitors cannot hold client money. Breach is a serious regulatory matter.
  1. Alternative Arrangements

19.1 As a Freelance Solicitor, you must ensure:

(a) Clients pay the instructing firm

directly;

(b) Or payments are made to a TPMA in appropriate

cases;

(c) Or payments are made directly between

parties;

(d) You never receive or handle client money personally.

19.2 You must advise clients of these arrangements in your engagement terms.

Part F: Aml and Client Money

  1. Source of Funds Verification

20.1 For all client money received, you must:

(a) Verify the source of

funds;

(b) Ensure funds are not proceeds of

crime;

(c) Apply CDD to source of

funds;

(d) Document verification

steps;

(e) Be satisfied funds are legitimate.

20.2 Enhanced verification is required for:

(a) Large or unusual

payments;

(b) Payments from third

parties;

(c) Cash or near-cash

instruments;

(d) High-risk

jurisdictions;

(e) PEP-related funds.

  1. Suspicious Transactions

21.1 You must be alert to:

(a) Payments that do not match the client's

profile;

(b) Unusual payment

methods;

(c) Third party payments without

explanation;

(d) Requests to return funds to different

parties;

(e) Complex or unusual transaction

patterns;

(f) Pressure to complete quickly without explanation.

21.2 If you suspect money laundering:

(a) Report to your MLRO or file SAR

directly;

(b) Do NOT proceed without NCA consent if

required;

(c) Do NOT tip off the

client;

(d) Document your concerns and actions.

  1. Third Party Payments

22.1 Third party payments into client account require:

(a) Identification of the third

party;

(b) Understanding of the reason for third party

payment;

(c) Verification of third party's source of

funds;

(d) Consideration of money laundering

risk;

(e) Client consent and understanding.

  • Third party payments are a money laundering red flag. Apply enhanced scrutiny per LSAG 2025.

Part G: Fca Requirements

  1. When FCA Applies

23.1 FCA client assets requirements may apply if you:

(a) Hold money in connection with FCA-regulated

activities;

(b) Conduct claims management

activities;

(c) Conduct consumer credit

activities;

(d) Are authorised by the FCA for any activities.

23.2 If FCA applies:

(a) FCA client money rules apply alongside SRA

rules;

(b) The more stringent requirement applies where

overlap;

(c) You must comply with CASS (Client Assets Sourcebook

);

(d) Additional reporting may be required.

  1. Client Assets Rules

24.1 FCA Client Assets (CASS) rules require:

(a) Segregation of client

money;

(b) Daily calculations and

reconciliations;

(c) Specific record-keeping

requirements;

(d) Client money reports to

FCA;

(e) Adequate arrangements acknowledgment letters.

24.2 You warrant that if FCA applies, you comply with all applicable CASS requirements.

Part H: Breach Notification

  • YOU MUST NOTIFY THE PLATFORM OF CLIENT MONEY BREACHES. FAILURE TO NOTIFY IS A SEPARATE BREACH OF THESE TERMS.
  1. Immediate Notification Events

25.1 You must notify the Platform IMMEDIATELY (within 24 hours) of:

(a) Any client money shortfall or

deficiency;

(b) Any use of client money for your own

purposes;

(c) Any misappropriation of client

money;

(d) Any fraud involving client

money;

(e) SRA investigation into client money

matters;

(f) Any intervention or threatened

intervention;

(g) Any conditions imposed on your practice relating to client

money;

(h) Any criminal investigation relating to client

money;

(

i

) Discovery that client money was proceeds of

crime;

(j) Any freezing order affecting client accounts.

🔔 NOTIFY PLATFORM: These are critical events. Notify immediately via the Platform's urgent notification procedure.

  1. Prompt Notification Events

26.1 You must notify the Platform promptly (within 7 days) of:

(a) Material breaches of SRA Accounts

Rules;

(b) Qualified Accountant's

Reports;

(c) Issues identified by reporting

accountants;

(d) Material reconciliation

discrepancies;

(e) SRA enquiries about client

money;

(f) Client complaints about money

handling;

(g) COFA concerns about

compliance;

(h) Bank concerns about client account

operation;

(

i

) Any other material client money issue.

  1. Notification Procedure

27.1 Notifications must be:

(a) In writing (email to [designated email]

);

(b) Marked as urgent for immediate notification

events;

(c) Contain full details of the

issue;

(d) Identify the potential

impact;

(e) Describe remedial action taken or

planned;

(f) Confirm whether SRA has been

notified;

(g) Provide regular updates as situation develops.

  1. Ongoing Reporting

28.1 Following initial notification:

(a) Provide updates at least weekly until

resolved;

(b) Notify of any SRA or other regulatory

contact;

(c) Confirm when matter is

resolved;

(d) Provide final outcome

report;

(e) Confirm lessons learned and remedial measures.

Part I: Indemnity Provisions

  • YOU FULLY INDEMNIFY THE PLATFORM FOR ALL CLIENT MONEY MATTERS.
  1. General Client Money Indemnity

29.1 You agree to indemnify, defend, and hold harmless the Indemnified Parties from and against all Claims and Losses arising out of or in connection with:

(a) Your handling of Client

Money;

(b) Your Client Account

arrangements;

(c) Any breach of SRA Accounts

Rules;

(d) Any client money shortfall or

deficiency;

(e) Any misappropriation of client

money;

(f) Any regulatory action relating to client

money;

(g) Any claim by any client relating to their

money;

(h) Any Compensation Fund

claims;

(

i

) Your failure to notify the Platform of breaches.

🛡 INDEMNITY: This indemnity covers ALL client money matters, regardless of whether you notified the Platform.

  1. Indemnity for SRA Breaches

30.1 You indemnify the Indemnified Parties against Losses arising from:

(a) Breach of SRA Accounts

Rules;

(b) SRA investigation into client

money;

(c) SRA disciplinary action for client money

breaches;

(d) Conditions imposed on your

practice;

(e) Intervention or threatened

intervention;

(f) Costs of SRA proceedings where Platform is

involved;

(g) Any regulatory fines or penalties.

  1. Indemnity for Client Losses

31.1 You indemnify the Indemnified Parties against Losses arising from:

(a) Client money lost or

stolen;

(b) Client money

shortfalls;

(c) Failure to account to clients for their

money;

(d) Interest not properly paid to

clients;

(e) Delays in returning client

money;

(f) Client claims for any money

issues;

(g) Client complaints to SRA or Legal Ombudsman.

  1. Indemnity for Regulatory Action

32.1 You indemnify the Indemnified Parties against Losses arising from:

(a) SRA

intervention;

(b) Appointment of intervention

agents;

(c) Freezing of

accounts;

(d) Criminal prosecution for theft or

fraud;

(e) Compensation Fund

payments;

(f) Law Society costs relating to

intervention;

(g) Any regulatory costs where Platform is involved.

  1. Indemnity for Third Party Claims

33.1 You indemnify the Indemnified Parties against Claims by:

(a) Clients whose money was

affected;

(b) Third parties claiming through

clients;

(c) Banks or financial

institutions;

(d) Other solicitors affected by your

breaches;

(e) Insurers seeking

subrogation;

(f) Any other third parties.

  1. Scope and Survival

34.1 The indemnities:

(a) Cover all direct

losses;

(b) Cover third party

claims;

(c) Cover regulatory fines and

penalties;

(d) Cover investigation

costs;

(e) Cover legal fees on an indemnity

basis;

(f) Cover settlement

amounts;

(g) Cover reputational damage

mitigation;

(h) Are NOT

capped;

(

i

) Survive termination of your Platform registration.

Part J: Platform Remedies

  1. Suspension

35.1 The Platform may immediately suspend your account if:

(a) You notify of an immediate notification

event;

(b) The Platform becomes aware of client money

concerns;

(c) SRA investigation is

announced;

(d) Intervention occurs or is

threatened;

(e) You fail to notify as

required;

(f) Material breach of these Terms occurs.

35.2 Suspension continues until:

(a) The matter is resolved to Platform's

satisfaction;

(b) Or termination

occurs;

(c) Or Platform is satisfied continuing is appropriate.

  1. Termination

36.1 The Platform may terminate your registration if:

(a) There is material misappropriation of client

money;

(b) SRA intervention

occurs;

(c) You are struck off or

suspended;

(d) Criminal proceedings are commenced for client money

matters;

(e) You fail to notify required

events;

(f) Material breach of these Terms occurs.

36.2 On termination:

(a) Indemnity obligations

continue;

(b) Notification obligations continue for past

matters;

(c) Cooperation obligations

continue;

(d) Outstanding fees remain payable.

  1. Reporting to Regulators

37.1 The Platform may report to the SRA if:

(a) You notify of serious client money

breaches;

(b) The Platform has reason to believe serious breaches

occurred;

(c) Required by law or

regulation;

(d) In the Platform's reasonable judgment, reporting is appropriate.

37.2 This is without prejudice to your own reporting obligations.

Part K: General Provisions

  1. Warranties

38.1 You warrant that:

(a) You comply with SRA Accounts

Rules;

(b) You maintain proper Client Accounts (unless Freelance Solicitor

);

(c) Your COFA is appropriately qualified and active (if applicable

);

(d) You perform reconciliations as

required;

(e) You obtain Accountant's Reports as

required;

(f) There are no current client money concerns or

breaches;

(g) You are not subject to conditions relating to client

money;

(h) You will notify the Platform of relevant

events;

(

i

) All information provided is true and accurate.

  1. Insurance

39.1 You warrant that:

(a) Your PII covers client money

claims;

(b) You are aware of policy terms regarding client

money;

(c) You have notified insurers of any client money

concerns;

(d) You will maintain adequate cover.

39.2 Failure of insurance to respond does not affect your indemnity obligations.

  1. Governing Law

40.1 This Agreement is governed by English law.

40.2 The courts of England and Wales have exclusive jurisdiction.

40.3 Each Indemnified Party may enforce indemnities under Contracts (Rights of Third Parties) Act 1999.

Schedule 1: Client Money Compliance Declaration

Client Money Compliance Declaration

I declare that:

Declaration

Confirmed

I comply with the SRA Accounts Rules 2019

I maintain proper Client Account(s) OR I am a Freelance Solicitor and do not hold client money

Client money is always kept separate from my own money

I perform reconciliations at least every 5 weeks

I obtain Accountant's Reports as required

I have a COFA in place (if applicable) OR I am a sole practitioner/freelance

There are no current client money shortfalls or concerns

I am not subject to any conditions relating to client money

There is no current SRA investigation into client money

I will notify the Platform of any material client money issues

I understand my indemnity obligations

If any declaration cannot be confirmed, provide details:



Signed: _______________________________________________

Name: _______________________________________________

SRA ID: _______________________________________________

Firm (if applicable): _______________________________________________

Date: _______________________________________________

SCHEDULE 2: BREACH NOTIFICATION FORM

Client Money Breach Notification

  • Complete this form for ANY client money breach or concern. Submit to [designated email].

Contact Details

Your Name: _______________________________________________

SRA ID: _______________________________________________

Firm: _______________________________________________

Contact Number: _______________________________________________

Email: _______________________________________________

Date of Notification: _______________________________________________

Nature of Issue

Issue Type

Applies

Client money shortfall

Misappropriation of client money

Breach of SRA Accounts Rules

SRA investigation

Intervention or threat of intervention

Conditions on practice (client money)

Qualified Accountant's Report

Criminal investigation

Client complaint (money)

Other (specify below)

Details of Issue

When did this occur/become known?


What happened?



Amount involved (if applicable): £_______________________________________________

Clients affected (number): _______________________________________________

Regulatory Notifications

Has SRA been notified? ☐ Yes ☐ No ☐ Will be notified

Date/planned date of SRA notification: _______________________________________________

Have insurers been notified? ☐ Yes ☐ No ☐ Will be notified

Remedial Action

What action has been/will be taken?



Signed: _______________________________________________

Date: _______________________________________________

Schedule 3: Client Money Compliance Checklist

Monthly/Regular Compliance Checklist

Check

Frequency

Last Completed

By

Client account reconciliation performed

Every 5 weeks minimum

All client ledgers balanced

Ongoing

No debit balances on client ledgers

Ongoing

Client money only used for permitted purposes

Ongoing

Receipts paid to client account promptly

Ongoing

Withdrawals properly authorised

Ongoing

Records properly maintained

Ongoing

Interest properly accounted for

As arising

COFA review completed (if applicable)

Regularly

Staff trained on client money

Annually

Annual Compliance Checklist

Check

Last Completed

Next Due

Accountant's Report obtained

Accountant's Report submitted to SRA (if required)

Issues from Accountant's Report addressed

Client money policy reviewed

Interest policy reviewed

Bank mandate reviewed

Signatories confirmed current

Training records updated

SCHEDULE 4: COFA CONFIRMATION

COFA Confirmation (Authorised Bodies Only)

This confirmation is provided by the COFA of the Authorised Body.

COFA Details

COFA Name: _______________________________________________

SRA ID: _______________________________________________

Date of SRA Approval as COFA: _______________________________________________

Firm Name: _______________________________________________

Firm SRA ID: _______________________________________________

COFA Confirmation

Confirmation

Confirmed

I am the approved COFA for this firm

I have appropriate authority to fulfil the COFA role

I have access to all relevant financial information

I have sufficient time and resources for COFA duties

The firm complies with SRA Accounts Rules

Reconciliations are performed as required

Accountant's Reports are obtained as required

There are no material client money concerns currently

I will ensure the Platform is notified of relevant issues

Signed: _______________________________________________

Date: _______________________________________________

SCHEDULE 5: INDEMNITY ACKNOWLEDGMENT

Acknowledgment of Indemnity Obligations - Client Funds

I acknowledge and confirm that:

Acknowledgment

Confirmed

I am solely responsible for compliance with SRA Accounts Rules

The Platform has no role in my client money arrangements

I indemnify the Platform for all client money claims

I indemnify the Platform for SRA Accounts Rules breaches

I indemnify the Platform for client money shortfalls

I indemnify the Platform for regulatory action (client money)

I indemnify the Platform for Compensation Fund claims

I must notify the Platform IMMEDIATELY of serious breaches

I must notify the Platform promptly of other material issues

Failure to notify is a separate breach of these Terms

The indemnities are NOT capped

The indemnities survive termination

I understand the Platform may report serious matters to SRA

I have adequate PII covering client money claims

Signed: _______________________________________________

Name: _______________________________________________

SRA ID: _______________________________________________

Firm (if applicable): _______________________________________________

COFA (if different): _______________________________________________

Date: _______________________________________________

Document Information

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Regulatory Framework

SRA Accounts Rules 2019

SRA Standards and Regulations 2019 (as amended 2025)

SRA Code of Conduct Rule 4 (Client Money and Assets)

SRA Compensation Fund Rules

Money Laundering Regulations 2017 (as amended)

Legal Sector Affinity Group Guidance 2025

Proceeds of Crime Act 2002

FCA Client Assets Sourcebook (CASS) - where applicable

Solicitors Act 1974 (intervention powers)

Contracts (Rights of Third Parties) Act 1999

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Related Documents

Platform Terms - Solicitor Indemnity and Liability V1.0

Platform Terms - SRA Compliance Validation V1.0

Platform Terms - KYC/AML Compliance V1.0

Solicitor Terms and Conditions V1.0

Privacy Policy V1.0

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Document Version: 1.0

Effective Date: January 2026

Last Updated: January 2026

Next Review: July 2026

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  • CLIENT MONEY IS SACROSANCT. You are solely responsible for compliance with SRA Accounts Rules. You indemnify the Platform for ALL client money matters. You MUST notify the Platform of any material breach or concern. Misappropriation of client money is theft and may result in criminal prosecution.