Client account must not be used as a banking facility (SRA Accounts Rules, rule 3.3)

Rule 3.3 of the SRA Accounts Rules provides that a firm must not use a client account to provide banking facilities to clients or third parties, and that payments into, and transfers or withdrawals from, a client account must be in respect of the delivery by the firm of regulated services. The sale is complete and the firm's bill is paid, so paying Tomasz's household bills, new business invoices and university fees would not relate to any regulated service the firm is delivering. In addition, rule 2.5 requires client money to be returned promptly to the client as soon as there is no longer any proper reason to hold it.

Why B is wrong: Rule 5.1(b) permits withdrawals on the client's instructions, but that does not override the separate prohibition in rule 3.3 on using client account as a banking facility.

Why C is wrong: The duty to account for interest under rule 7 applies to money properly held; it does not make an otherwise prohibited arrangement permissible.

Why D is wrong: No approval by the COFA can authorise a use of client account that rule 3.3 prohibits.

Why E is wrong: Once the transaction is completed and the bill paid, there is no proper reason to hold the money, and the proposed payments are unconnected with the delivery of regulated services.