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    Alternative Arrangements

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    Introduction

    1. Introduction: Alternative Arrangements for Holding Client Money

    Most of the time, money you receive for a client goes into a dedicated client account in the firm's name, with the full SRA Accounts Rules applying. But practice throws up situations where that isn't the right tool — funds held jointly with another party, money sitting in an account in the client's own name, or payments handled by a regulated third party so the firm never touches the cash. Each of these alternatives shifts the rules: some duties survive, some disappear, and the regulatory protection can move from the SRA to the FCA entirely. Knowing the difference keeps you compliant and lets you reassure clients about how their money is held.

    What this lesson covers:

    1. Default Position, Alternatives and Joint Accounts — the standard client account starting point, the three recognised alternatives, and how joint accounts work and what compliance survives.
    2. Client's Own Account (Solicitor as Signatory) — operating an account in the client's name as signatory, why it isn't a client account, and the record-keeping that still applies.
    3. Third Party Managed Accounts (TPMAs) — using an FCA-regulated escrow provider, when the money is and isn't client money, and what you must tell the client first.
    4. Regulatory Protection and Distinctions — how the protection for a client account differs from a TPMA, and where SRA and FCA regulation each apply.

    Next: 2. Default Position, Alternatives and Joint Accounts

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