Key Takeaways

  • Massachusetts brokers must maintain a separate trust (escrow) account for client funds
  • Trust accounts must be in a Massachusetts bank or savings institution
  • Commingling personal funds with client funds is prohibited
  • Brokers must maintain complete records of all trust account transactions
  • Interest-bearing accounts require special authorization from clients
Last updated: January 2026

Trust Account Requirements

Massachusetts requires brokers to properly handle client funds through trust (escrow) accounts.

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Trust Account Basics

Account Requirements

RequirementDetails
Separate accountCannot be personal account
Massachusetts bankMust be in MA
Account titleMust identify as trust account
FDIC insuredBank must be insured
Demand depositMust be readily accessible

Account Titling

The trust account must be titled to show:

ElementExample
Broker name"ABC Realty"
Trust designation"Trust Account" or "Escrow Account"
Full title"ABC Realty Trust Account"

What Belongs in Trust Account

Client Funds

Deposit TypeExample
Earnest moneyBuyer deposits
Security depositsRental deposits
Rent collectedFor property management
Other client fundsAs required

What Does NOT Belong

Do Not DepositReason
Personal fundsCommingling
Commission (before earned)Not yet due
Operating expensesBusiness account
Personal savingsCommingling

Trust Account Rules

Prohibited Practices

ProhibitedConsequence
ComminglingLicense discipline
ConversionCriminal charges possible
Unauthorized withdrawalsLicense revocation
Interest diversionUnless authorized

Commingling vs. Conversion

TermDefinition
ComminglingMixing personal and client funds
ConversionUsing client funds for personal use

KEY EXAM POINT: Commingling is mixing funds; conversion is stealing/using them. Both are violations, but conversion is more serious.

Record Keeping

Required Records

RecordPurpose
LedgerTrack all transactions
Bank statementsMonthly reconciliation
Deposit receiptsProof of deposit
Disbursement recordsTrack withdrawals
Client ledgerPer-client balances

Retention Period

DocumentKeep For
Trust records3 years minimum
Transaction files3 years after closing
Reconciliations3 years

Interest-Bearing Accounts

IOLTA (Interest on Lawyers Trust Accounts)

FeatureDetails
PurposeSmall deposits, short term
Interest goesTo legal aid programs
No client authorizationFor qualifying funds

Client Interest

SituationRequirement
Large depositsMay require client authorization
Long-term holdsInterest may go to client
Written agreementDocument arrangements
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Massachusetts Trust Account Requirements
Test Your Knowledge

What is the difference between commingling and conversion?

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Test Your Knowledge

Where must a Massachusetts broker maintain a trust account?

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