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Corporate banking

Banking a real estate or property company

Brokerage, development and property holding are three different banking conversations. Only one of them involves an escrow account, and mixing client money with your own is the regulatory failure that ends brokerages.

Three models very differentRERA escrow for developersClient money segregate

The reality

What the bank is actually deciding.

Real estate covers activities with almost nothing in common from a banking perspective. A brokerage earns commission, holds no client funds in the ordinary case, and is essentially a professional services business with a RERA registration. A developer selling off-plan is required to route purchaser funds through a project escrow account supervised under the escrow law, which is a specific regulated product rather than an ordinary corporate account. A property holding company owns assets and receives rent, and looks like an SPV. Applying for the wrong product wastes weeks.

The recurring failure in this sector is client money. Brokers receive deposits, cheques and transfer amounts on behalf of buyers and sellers, and the temptation to run them through the operating account is strong because it is simpler. It is also the thing that ends brokerages: a commingling finding is a regulatory matter with RERA as well as a banking one, and it is discovered when a transaction goes wrong and somebody's deposit is not where it should be. A separate client account, reconciled, is not optional in substance even where the structure permits it.

What gets asked for

Brokerage
RERA registration; commission income; segregate client money
Developer
Project escrow account required under the escrow law
Holding
SPV profile — rental income and asset ownership
Escrow
A regulated product, not an ordinary corporate account
Commingling
A regulatory failure as well as a banking one
Golden Visa link
Property at AED 2m supports a residence application

Where the time goes

BrokerageCommission incomeA professional services profile with RERA registration — and segregated client money.
Property holding companyAsset ownershipAn SPV profile, which needs a written structural rationale.
Developer selling off-planEscrow requiredA supervised project escrow account under the escrow law, not an ordinary corporate account.
Three businesses with almost nothing in common at a bank. Applying for the wrong product wastes weeks.

The file

What to put in front of them.

  1. Identify which of the three you actually areThe banking product, the documentation and the regulator differ completely.
  2. For brokerage, open a segregated client accountFrom the start. Retrofitting segregation after a dispute is not a defence.
  3. For development, engage on escrow earlyThe escrow account is a condition of selling off-plan and involves the authority as well as the bank.
  4. For holding, write the structural rationaleAs with any SPV — what is held, why it is separate, what flows are expected.
  5. Keep RERA registration currentA lapsed registration is visible and undermines the whole file.
The mistake people make. Running client deposits through the operating account because it is one less account to reconcile. It is the single most common cause of regulatory action against brokerages, and it is entirely avoidable at the cost of a second account.

Related

Questions

In substance yes. Commingling client deposits with operating funds is the most common regulatory failure in the sector.

A supervised account through which purchaser funds for an off-plan project must pass, required under the escrow law. It is a regulated product, not an ordinary corporate account.

It has an SPV profile — low activity, no customers — so it needs a written structural rationale like any holding vehicle.

AED 2 million of registered UAE property supports a five-year Golden Visa, which is a separate matter from the company's banking.

One question

Where will the money actually come from?