4.32 Commingling & Conversion

Depositing any trust funds into the Company’s operating account is prohibited and considered commingling. In the event that trust funds are mistakenly deposited into the operating account in error, the funds must be immediately returned to the proper trust fund account. Details of the error should be recorded in the bookkeeping software. Any funds made out directly to an Associate of the Company is prohibited. An Agent/Loan Officer cannot receive funds in their personal name or their entity name from clients for commissions, management fees, credit reports, appraisals, marketing, or inspection fees or any other type of fee. Agents cannot deposit any type of fee into his or her operations account. This is conversion and/or commingling because these funds are trust funds that should be held by the Company. If a client mistakenly sends or gives funds to an Agent/Loan Officer in error, the Agent / Loan Officer must return the funds immediately and instruct the client to make out the funds payable to the Company to be held in a trust account.