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CQS Mortgage and Property Fraud Prevention Policy - What to Include

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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
  • Introduction
  • Client Due Diligence
    • Identity of the Client and Client's Circumstances
    • Linked Transactions
  • External Parties
    • Identity of the Other Lawyers
  • Financial Considerations
    • Proceeds of Sale
    • General Considerations
      • Proceeds being sent to non-client
      • Variations in price, incentives and other material considerations
  • Risk Assessment and Valuations
    • Valuations
    • Mortgage Fraud Schemes
    • Types of Property Fraud
  • Safeguarding and Security
    • Safeguarding the Firm’s Client Account
    • Buyer-funded Developments
    • Unencumbered Property
  • HM Land Registry Procedures
    • General
    • HMLR Requisitions Procedure
    • HMLR Registration Procedure
  • Governance
    • Warning Signs
    • Monitoring & Review
    • Acknowledgement Provision
  • Appendix
    • Labels:

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