Changing Trust Accounts: A Compliance Checklist for Property Managers

Sonia Mammino-Rahme
May 27
3 min read

Changing trust bank accounts might seem like a quick admin task. But for property managers, it’s a process steeped in regulatory requirements, detailed communication, and meticulous record-keeping. One wrong move can result in compliance breaches, disrupted payments, or big fines. To help you avoid the stress, we’ve compiled a step-by-step compliance checklist designed specifically for changing trust accounts in the real estate industry.

1. Notify All Key Parties (Early and Clearly)

Before anything else, ensure that all stakeholders are informed; tenants, landlords, creditors, and suppliers. These parties rely on consistent payment references and bank details. If communication is missed or delayed, expect misdirected payments and unnecessary confusion.

Send formal email notifications with the new trust account details.
Provide a clear cut-off date for when the old account will no longer be in use.
Consider a follow-up reminder one week before the changeover.

Tip: Ensure all automated payment systems (like tenant rent transfers or recurring supplier payments) are updated by all parties.

2. Set and Communicate a Cut-Off Date

Transferring trust accounts requires a seamless transition, not simply opening a new account.

Set a firm cut-off date for accepting deposits into the old account.
Give at least 14 days' notice to all payees.
Internally, lock in your date for ceasing to disburse from the old account.

This helps prevent double handling, errors in reconciliation, and missed funds during the switch.

3. Reconcile the Old Account Before Closing

Before closing the old trust account, it must be fully reconciled and cleared. This step is often rushed, but skipping it can result in audit issues or even unclaimed funds down the track.

Ensure all disbursements have been processed.
Match deposits to expected transactions.
Leave no balance behind unless it's accounted for.

Under NSW legislation, unclaimed trust money must be managed through Revenue NSW if held for more than two years.

4. Choose the Right Bank with Trust-Specific Functionality

Not all bank accounts are created equal. A trust account requires specific functionality, including restrictions on fund use and authorised access.

According to NSW Fair Trading, “Licensees under the Property and Stock Agents Act 2002 (the Act) must hold clients’ funds in a trust account. Those funds cannot be used for any purpose other than for that client and must be disbursed as the client directs.”

Make sure your chosen financial institution is on the approved list of Authorised Deposit-Taking Institutions (ADIs). Some of the major approved banks include Westpac, NAB, Commonwealth Bank, and Macquarie.

5. Notify Relevant Authorities…and Don’t Delay

A major compliance trap is forgetting to notify NSW Fair Trading when opening or closing a trust account.

When opening a new account, apply for a Unique Identifying Number (UID) through NSW OneGov and lodge this with your bank.
When closing an account, complete the required notification within 14 days. You’ll need to email your form to StatutoryInterestUnit@customerservice.nsw.gov.au.

Failure to comply can result in fines or audit flags, so don't skip the documentation work.

6. Final Tip: Keep Detailed Records for Three Years

Once the process is complete, store all relevant documentation, reconciliations, and authority communications securely. NSW regulations require trust account records to be kept for a minimum of three years after account closure.

Need Help Changing Trust Accounts?

At Think Cloud Solutions, we understand that changing trust accounts is more than just updating BSBs. It’s about staying compliant, organised, and stress-free.

Whether you’re switching banks, restructuring your trust setup, or just want expert oversight, our team can manage the transition from start to finish, no matter how complex your requirements are.