[Tiffany Woodhall]

In your case:

43 days and a likely high balance = yes, interest should be calculated and credited (unless your interest policy states otherwise and the client has been informed).

This is likely why your auditor flagged the lack of interest but not the retention — they focused on Rule 7.1 rather than Rule 3.3.

Auditors often take a risk-based approach:

If the funds were clearly linked to an ongoing transaction (so Rule 3.3 not clearly breached),

But no interest was applied, that’s a technical breach of Rule 7.1 and easier to evidence on the ledger.

So — they may have noted the holding period as acceptable given the circumstances, but interest omission as a non-compliance.

[Tiffany Woodhall]

There’s no fixed number of days in the SARs, but guidance and audit practice generally suggest:

Up to 14 days is acceptable where there’s a clear and imminent link between sale and purchase.

Up to 4 weeks might be reasonable if both transactions are ongoing and the delay is procedural (e.g. awaiting searches or mortgage offer).

Beyond 4–6 weeks, without a confirmed completion date, the SRA expects funds to be returned to the client unless there’s a compelling reason and you have documented it clearly on file.

At 8 weeks, as in your scenario, retaining the funds would almost certainly be deemed too long and non-compliant unless there’s a court order, probate restriction, or other legal necessity that justifies it.

[Tiffany Woodhall]

Hi
This is because Nationwide are not a direct member of the Clearing House Automated Payment System ( we know as CHAPS) so HSBC are the intermediary bank to route funds

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