Achekam

Trust audit, review or exemption for agencies

Whether a South African estate agency needs a trust audit, an independent review or an exemption, and how to get its books ready for the auditor.

By Achekam · · 4 min read · For Real estate businesses in South Africa

PPRA trust account audit exemption

Every year, around the same time, a South African agency principal asks the same question: do we need a full audit this year, or is a review enough? And every year the answer depends on two things the principal should know without looking up: whether the agency handles trust money at all, and what its revenue was.

The Property Practitioners Regulatory Authority has set out the combinations clearly. The difficulty is less in the rules than in organising the year so that the auditor or reviewer can do the work within the deadline. This article sorts the agency into the right category and then looks at preparing the books.

Agencies that keep a trust account

The PPRA says a business property practitioner without a trust account exemption must open and keep a trust account under section 54(1) of the Property Practitioners Act, and have it audited annually by an IRBA-registered auditor within 6 months of its financial year-end.

That trust audit is not optional and does not depend on size. If the agency holds deposits for buyers or tenants in a section 54 trust account, the account is audited.

The financial statements are a separate question. The PPRA says a business property practitioner with a trust account must have its annual financial statements audited by the same registered auditor if its revenue is at least R2,5 million, or independently reviewed by that auditor if revenue is below R2,5 million, again within 6 months of year-end. Those are the figures at the time of writing; confirm them with the PPRA before the year-end.

Agencies that handle no trust money

Some agencies never touch client money. Deposits go straight to the conveyancer, or the agency uses a Payment Processing Agent. The PPRA says a business property practitioner that does not handle trust money, or uses a Payment Processing Agent, must apply for a trust account exemption letter under section 23(2) of the Act, after which it no longer submits an annual trust account audit report.

The exemption does not mean no outside scrutiny at all. The PPRA says the annual financial statements of an exempt business property practitioner must be independently reviewed regardless of revenue. Who may do the review depends on the entity:

  • a company with a public interest score of 100 or more needs a registered auditor or a chartered accountant;
  • otherwise, a person qualified as a close corporation accounting officer may also do it.

Which one applies to you

A quick way to place the agency:

The agency...Trust accountFinancial statements
Holds trust money, revenue at least R2,5 millionAudited by an IRBA-registered auditorAudited by the same auditor
Holds trust money, revenue below R2,5 millionAudited by an IRBA-registered auditorIndependently reviewed by the same auditor
Has a trust account exemption letterNo annual trust audit reportIndependently reviewed, whatever the revenue

Everything in the first two rows must be done within 6 months of the financial year-end. If the agency runs several entities, each one is placed separately; see running several agency entities.

The PPRA's audit compliance page sets out the audit, trust account and accounting requirements for business property practitioners, including the exemptions, and is the authority to check against each year.

The auditor's appointment and the PPRA's records

Under section 54(1) of the Act, a property practitioner must appoint an auditor immediately after opening a trust account, and then give the Authority all information about the account and the auditor. Section 54(14) adds that the practitioner must confirm or update its auditor's details every year, as prescribed.

The PPRA also runs an Auditors Portal for property practitioners' trust account audits, and publishes audit compliance guidelines, information on trust account exemptions and information for auditors. Ask your auditor early in the year how they will use it and what they need from the agency.

A short annual calendar helps:

  1. Shortly after year-end: confirm or update the auditor's details with the PPRA.
  2. First month after year-end: close the books for the last month of the year.
  3. Second and third months: the auditor or reviewer does the fieldwork.
  4. Well before the sixth month ends: reports signed and submitted.

Getting the books ready in Achekam

Most delays in a trust audit or review are caused by books that keep changing while the auditor is reading them. Two features help.

Close the months. In Achekam, months can be soft-closed, hard-closed and locked, and a closed month refuses postings from every source. Reopening a hard close needs a second approver. Before a month closes, the screen checks that the ledger balances and that no posting suggestions, unposted bills or unmatched bank lines are waiting. Hard-close every month of the financial year before the auditor starts, so the figures they test are the figures that stay.

Appoint the auditor with the right access. A business appoints its accounting firm by the firm's Achekam address or firm code, as accountant, auditor, tax practitioner, payroll provider or adviser, with an access level, and the firm accepts or declines. What the firm's people can then do depends on that level: bookkeeping access covers the accounting but not the business's users, settings or payment gateways, and review access is read-only. For an audit or independent review, read-only review access is usually the right choice, because the auditor needs to see every figure but should not change any of them. The trade-offs are covered in accountant review access.

These features cover the agency's own business books. The separate trust records the Act requires, and the trust bank statements, still need to be ready for the same auditor at the same time.

Before this financial year ends, decide which row of the table applies to the agency, confirm the auditor's details with the PPRA, and agree a fieldwork date that leaves room inside the six months.

General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.

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