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What Should Be Reported to the COFA?

A 50-point financial compliance and regulatory escalation checklist for law firms

Help your team recognise the financial, regulatory and operational issues that should be reported to the COFA. This practical checklist provides a clear framework for identifying concerns early, escalating them promptly and supporting stronger oversight of client money, financial controls and SRA Accounts Rules compliance.

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Why This Resource Matters

The responsibility for reporting concerns does not sit with the accounts team alone. Fee earners, support staff, managers and compliance personnel may all encounter issues that require COFA attention, and delays can make a relatively contained problem harder to investigate and resolve. This checklist helps firms create a clearer reporting culture by showing staff what to look out for and reinforcing the importance of escalating concerns as soon as they are discovered.

What’s Included in the Checklist

The checklist covers 50 common financial and regulatory concerns, including client account shortages, incorrect or duplicate payments, residual balances, reconciliation failures, fee disputes, suspected fraud, data loss, AML breaches and regulatory correspondence. It also includes a review framework to help the COFA assess the cause, impact and reportability of each issue, including whether it should be recorded, referred internally or reported to the SRA.

This checklist is suitable for:

  • COFAs
  • COLPs
  • Managing partners
  • Finance and accounts teams
  • Practice managers
  • Fee earners
  • Compliance personnel
  • Support staff handling payments, billing or client money

Need Further Support?

If your firm needs help reviewing an incident, deciding whether a matter is reportable or strengthening its financial compliance controls, RACO can provide practical support. Our services include COFA support, Accounts Rules reviews, compliance register administration, regulatory guidance and ongoing Risk & Compliance Management for law firms.


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What Should Be Reported to the COFA?
What Should Be Reported to the COFA? Checklist Resource

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