CLIENT ACCOUNT INFORMATION

Version: 2019-001 Last Modified: February 11, 2019

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Who is required to submit the client account documentation? You are required to submit the client account documentation if you:

1) completed the Client Account course, and 2) are requested by ICCRC to submit the Compliance Audit Full Submission.

NOTE: If you have more than one (1) client account, you are required to submit the client account documentation for each client account. If you have received an exemption by ICCRC from opening and/or maintaining a client account and if you declare that, since signing the prescribed declaration form, you have not received money to be held on behalf of a client for: a. future unbilled services; b. overpayment of billed services; c. government processing fees; or d. any other type of disbursements, then you are not required to submit the client account documentation for the compliance audit. If you have had a client, but there were no monies in your client account for either March, April or May if you are submitting for the July 1 deadline, or one of the three months prior to your one-year anniversary with the Council, you are required to submit a copy of your client account bank statement for one (1) of the indicated months (in order to demonstrate compliance with Section 3.1 of the Client Account Regulation). You are also required to submit an explanation as to why there were no monies in your client account for those particular months. What must be submitted? The client account documentation includes:

a. Client account bank statement A bank statement is issued by the financial institution and usually contains the word “statement”. A bank statement has the following components:

• name of financial institution (see Section 2.2.f of the Client Account Regulation for the definition of financial institution),

• account holder’s name and address, • account number, • period of statement covering one month (e.g., May 1-May 31), • opening and closing balances, and • details of transactions (i.e., deposits and withdrawals).

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Notes on “a”: • Documents such as “Account Activity”, “Account Details”, “Transaction details”,

“Transaction History” etc., do not contain all of the required components, as listed above.

• In the event your financial institution does not provide the type of statement described in part “a” above, please provide supporting documentation which addresses each of the required components (e.g., a signed letter from your financial institution which includes all of the required components or a combination of official documents that presents the required information).

In order to protect client confidentiality, black-out any client names or client contact information that appears on the bank statement.

See Appendix A for a sample bank statement.

b. Detailed client account reconciliation statement The detailed client account reconciliation statement is a bookkeeping record where you document all transactions (i.e., all deposits and withdrawals, as well as pending transactions) that have taken place in your client account during a particular month. As presented in the Client Account course, the detailed client account reconciliation statement contains seven (7) mandatory components, as detailed below:

1. Client account balance as of the end of the previous month (e.g., Apr. 30) 2. Less withdrawals cleared from the client account for the month being reported (e.g.,

May) 3. Add deposits made to and cleared from the client account for the month being reported

(e.g., May) 4. Client account balance as of the end of the month being reported (e.g., May 31) 5. Less withdrawals NOT cleared from the client account as of the end of the month being

reported (e.g., May 31) 6. Add deposits made but NOT yet cleared from the client account as of the end of the

month being reported (e.g., May 31) 7. Equals consultant’s client liability account balance as of the end of the month being

reported (e.g., May 31) NOTE: Component seven (7) must equal the client list total.

Remember to include the details (i.e., date, client code, transaction description and amount) for each transaction (i.e., deposit and withdrawal, as well as pending transaction) listed under mandatory components 2, 3, 5, and 6 (listed under “b” above) of the detailed client account reconciliation statement. If there is nothing to report for one or more components, indicate “0” next to the component.

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In order to protect client confidentiality, use client codes on the detailed client account reconciliation statement. An example of a client code is: SH_123 (client’s initials and a number). Please refer to samples provided on pages 18-22 of the Client Account Workbook for further clarification. A Detailed Client Account Reconciliation Statement template is available online and in Appendix B.

c. Client list

The client list indicates the amount of money that you are holding on behalf of each client as of the end of the month being reported. The client list also contains the client codes of all clients for which you held unearned client money in the client account during that particular month. A client list is not the same as the “Active Client File Register”, which was presented in the Client File Management course. If you have a reasonable amount of money in the client account, as of the end of the month being reported, to cover bank fees, list and identify the amount on the client list. Please use the Client List Template, which is available online, on page 26 of the Client Account Workbook and in Appendix C. In order to protect client confidentiality, use the same client codes from the detailed client account reconciliation statement. An example of a client code is: SH_123 (client’s initials and a number).

Notes on “a-c”:

• All three documents (a-c) must be for the same month (e.g., May). • Submit the three documents for one (1) month (either: March, April or May if you

are submitting for the July 1 deadline, or one of the three months prior to your one-year anniversary with the Council).

• All three documents must protect client confidentiality.

Common issues with compliance audit submissions The following issues were identified when reviewing compliance audit submissions. The identified issues are listed in the left column of the chart below and the corresponding correct approaches are listed in the right column in the chart below.

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Common issue Correct approach • The RCIC submitted an “Account Activity”

document, but not a client account bank statement.

• The “Account Activity” statement alone is

insufficient as it may not indicate the account holder’s name and address, the period of statement covering one month (e.g., May 1-May 31), or the opening and closing balances. Submit either a bank statement or supporting documentation, as described under “Client account bank statement” above.

• The client account bank statement does not detail

a one (1) month period.

• The client account bank statement must detail a

one (1) month period (e.g., May 1-May 31).

• The detailed client account reconciliation

statement contains client names or client contact information.

• This is a breach of client confidentiality, according

to Article 8.1 of the Code of Professional Ethics. To protect client confidentiality, black-out client names and/or client contact information on the bank statement and use client codes for the detailed client account reconciliation statement and the client list.

• The detailed client account reconciliation

statement is missing mandatory components 5-7.

• The detailed client account reconciliation

statement must contain all seven (7) mandatory components (listed under “Detailed client account reconciliation statement” above), and it must contain the details for the relevant component. If there is nothing to report for a given component, indicate “0”.

• The detailed client account reconciliation

statement does not contain the details (i.e., date, client code, transaction description and amount) for the transactions (i.e., all deposits and withdrawals, as well as pending transactions) listed under components 2, 3, 5 or 6.

• Include the details (i.e., date, client code,

transaction description and amount) for each transaction (i.e., deposit and withdrawal, as well as pending transaction) listed under components 2, 3, 5 and 6. Consider using the Detailed Client Account Reconciliation Statement Template which is available online and in Appendix B.

• The client list is not in the correct format or an

“Active Client File Register” has been submitted in place of a client list.

• Please use the Client List Template, which is

available on line and in Appendix C, when preparing and submitting the client list to ICCRC.

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Common issue Correct approach • The client list does not include all of the client

codes and the amount held on behalf of the client at the end of the month being reported.

• The client list must represent, using client codes

rather than client names, all clients for which you have unearned client funds in your client account by the end of the month being reported. Furthermore, if money was withdrawn from the client account during the month being reported and there are no longer funds held on behalf of a client by the end of the month being reported, the client code and amount held on behalf of the client (i.e., “0”) must be included on the client list.

• There is RCIC money in the client account as of

the end of the month being reported.

• According to Article 2.2.9.iv of the Code of

Professional Ethics and Section 8.1 of the Client File Management Regulation, RCIC and client money is to be segregated and only a reasonable amount of RCIC money is permitted to be deposited to the client account to cover administrative fees (Section 5.1.a of the Client Account Regulation). If, at the end of the month being reported, you have a reasonable amount of money in the client account to cover bank fees, list and identify it on the client list.

• Client money is being held in the client account that is for the benefit of a third party.

• A RCIC shall not hold client money for the benefit

of a third party except for money to pay the RCIC’s fees, including agent’s fees, application fees, and disbursements. For greater clarity, the prohibition on holding client money includes money the client needs to be eligible for any program under the IRPA or the Citizenship Act (Section 5.1.b of the Client Account Regulation).

• The bank statement, detailed client account

reconciliation statement and client list do not all represent the same month (e.g., May).

• All three client account documents must

represent the same month (either: March, April or May for the July 1 deadline, or one of the three months prior to your one-year anniversary with the Council).

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Appendix A Client Account Bank Statement Sample

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Appendix B Detailed Client Account Reconciliation Statement Template

This template is provided by ICCRC for RCIC’s use and consideration when undertaking the monthly client account reconciliation (see Section 9.1 of the Client Account Regulation) and when submitting for the

compliance audit. The seven (7) components below are mandatory for the detailed client account reconciliation statement; however the formatting may vary based on the system of record keeping used.

Detailed Client Account Reconciliation Statement

[insert RCIC’s name or RCIC’s Company name] [insert month being reported—e.g., May 31, 2013]

1 Bank Balance as of [insert last day of month prior to month being reported]

2 Less withdrawals cleared from the CA

for the month of [insert month and year of month being reported]

Date Method of transaction

Client code Amount

Bank fees (as applicable) Total

Withdrawals

3 Add deposits made to and cleared

from the CA for the month of [insert month and year of month being reported]

Date Method of transaction

Client code Amount

Bank fees (as applicable) Total Deposits

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4 Client Account Balance as of [insert

month and year being reported]

5 Less withdrawals NOT yet cleared

from the CA as of [insert final day of month being reported]

Date Method of transaction

Client code Amount

Total

Outstanding Withdrawals

6 Add deposits made to but NOT yet

cleared from the CA as of [insert final day of month being reported]

Date Method of transaction

Client code Amount

Total

Outstanding Deposits

7 Book (Client Liability Account)

Balance as of [insert final day of month being reported]

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Appendix C Client List Template

This template is provided by ICCRC for RCIC’s use when undertaking the monthly client account reconciliation (see Section 9.1 of the Client Account Regulation) and when submitting for the

compliance audit.

Client List

Money held on behalf of each client

As of __________________________ (insert month, day and year)

Client(s)

(protect client confidentiality by using client codes—do NOT use client names)

Amount held on behalf of each client

Deposited in CA ()

□ □ □ □ □ □ □ □ □ Bank fees (as applicable) □ TOTAL: This number MUST EQUAL the Client Liability Account balance (component 7), as of the end of this particular month.