Solicitors' & Conveyancers' Accounts
Client account, the SRA Accounts Rules, the CLC Accounts Code and legal cashiering in practice.
These answers provide general information, not advice tailored to your circumstances. Rules can change and exceptions may apply — speak to the CASS team before making a tax, accounting or financial decision.
In an SRA-regulated firm in England and Wales, the COFA must take all reasonable steps to ensure the firm complies with the SRA Accounts Rules, and to ensure that facts or matters they reasonably believe are capable of amounting to a serious breach are reported promptly to the SRA. There is also a wider duty to bring relevant facts and matters to the SRA's attention. The COFA role does not remove the compliance responsibilities of the firm's managers, and it is not the same as the day-to-day cashiering work. CLC-regulated practices work to a different framework, where the HOFA and managers have their own reporting duties.
Reviewed by Paul Barnes, Founder, Cloud Accounting Support Services · Last reviewed 2 October 2026
The Head of Finance and Administration, or HOFA, is a formal role in a CLC-regulated alternative business structure. They oversee compliance with the CLC's requirements for handling money and must promptly report breaches of those requirements to the CLC. The HOFA must also promptly report when the practice is in financial distress or at significant risk of becoming financially distressed. Where misappropriation of client funds is discovered, the practice must notify the CLC without delay and replace the shortfall without delay. The practice and its managers retain their own responsibilities: appointing a HOFA or outsourcing legal cashiering does not transfer all accountability to that person or provider.
Reviewed by Paul Barnes, Founder, Cloud Accounting Support Services · Last reviewed 2 October 2026
A client account reconciliation compares the client bank account, client ledger balances and relevant accounting records so differences can be identified and investigated.
Reviewed by Paul Barnes, Founder, Cloud Accounting Support Services · Last reviewed 29 September 2026
Legal cashiering covers the processing and control of financial transactions within a legal practice, including work involving office and client money: postings, transfers, reconciliations and the records that evidence them. It supports the firm's compliance with the relevant SRA Accounts Rules or CLC Accounts Code, but it is not the same as an audit, and legal cashiering does not itself include a regulatory accountant's report. The firm's managers, COFA or HOFA keep their own responsibilities.
Reviewed by Paul Barnes, Founder, Cloud Accounting Support Services · Last reviewed 2 October 2026
Legal cashiering maintains the practice’s day-to-day financial records and supports controls such as reconciliations. A regulatory accountant’s report is a separate assessment prepared by an eligible reporting accountant under the applicable rules. Requirements and exemptions differ between SRA and CLC practices. CASS’s legal cashiering service does not itself replace or include that report; any reporting accountant appointment needs to be arranged separately.
Reviewed by Paul Barnes, Founder · Last reviewed 2 October 2026
Someone who works in your software, knows whether you are regulated under the SRA Accounts Rules or the CLC Accounts Code (England and Wales), reconciles to the required timetable, evidences what they have done, and escalates breaches and residual balances rather than leaving them. Ask how cover works when your cashier is away. The points below are good practice we recommend, not regulatory requirements: your own oversight and accountability stay with the firm either way.
Reviewed by Paul Barnes, Founder, Cloud Accounting Support Services · Last reviewed 2 October 2026
Agree the transfer of client and office balances, matter histories, outstanding items and supporting records before switching. Reconcile the old system, verify opening balances in the new system and preserve access to required historical records. Test permissions, approvals and reporting, and plan responsibility for the changeover. A software move does not suspend regulatory duties. CASS can discuss cashiering support for practices using InTouch within an agreed scope.
Reviewed by Paul Barnes, Founder · Last reviewed 2 October 2026
Escalate it immediately to the responsible compliance officer and managers. Investigate the cause and protect client money; do not use another client’s funds to cover it. SRA firms must promptly correct breaches and immediately replace missing money, while CLC practices must replace shortfalls without delay. Reporting duties depend on the regulator and circumstances; CLC misappropriation must be notified without delay. Do not wait for the next reconciliation to act.
Reviewed by Paul Barnes, Founder · Last reviewed 2 October 2026
Check who is entitled to it and return it promptly once there is no proper reason to retain it. If the recipient cannot be traced, document your attempts and follow your regulator’s residual or aged-balance procedure. SRA and CLC procedures differ, so do not apply one regulator’s thresholds to the other. Small balances cannot simply be transferred to office account because a matter has ended.
Reviewed by Paul Barnes, Founder · Last reviewed 2 October 2026
Only when the transfer is permitted by the applicable regulator’s rules, properly authorised and supported by sufficient funds for that client or matter. For SRA firms, transferring money for costs requires a bill or other written notification identifying the relevant costs before transfer. CLC practices follow their own permitted-withdrawal requirements, including properly submitted invoices where applicable. Raising an invoice alone does not make every transfer permissible.
Reviewed by Paul Barnes, Founder · Last reviewed 2 October 2026
