It’s one thing to say you have a Mortgage and Property Fraud Prevention Policy; it’s another to have a document that actually works under pressure. If you are currently updating your firm’s manual to meet CQS requirements, you don’t need to reinvent the wheel. Below is a sample index of what a ‘gold-standard’ CQS Mortgage and Property Fraud Prevention Policy looks like. Use this as a checklist to identify gaps in your current procedures and ensure you’re hitting all the mandatory CPMS requirements
- Identity of the Client and Client’s Circumstances
- Linked Transactions
- Identity of the Other Lawyers
- Proceeds of Sale
- General Considerations
- Proceeds being sent to non-client
- Variations in price, incentives and other material considerations
- Valuations
- Mortgage Fraud Schemes
- Types of Property Fraud
- Safeguarding the Firm’s Client Account
- Buyer-funded Developments
- Unencumbered Property
- General
- HMLR Requisitions Procedure
- HMLR Registration Procedure
- Warning Signs
- Monitoring & Review
- Acknowledgement Provision
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