Singapore conveyancing money: who holds your deposit, and how

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Kooky

Builder of Shaka, the payment router that pays every agent their commission on closing date.

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A buyer who exercises an option on a Singapore home hands over, in one cheque, a sum that most households take years to save. For the weeks between that payment and completion, the money belongs fully to neither side: the seller has not yet handed over the property, and the buyer can no longer spend the deposit. Somebody has to hold it. Who that somebody may be, and what they are allowed to do with it, has been fixed by rules in Singapore since 1 August 2011.

This guide sets out those rules as the Ministry of Law, the Singapore Academy of Law, the Council for Estate Agencies and the CPF Board describe them. It covers what counts as conveyancing money, the three places a lawyer may keep it, the suffix that belongs on the cheque, the two signatures needed to move the money out, how the Academy's stakeholding service runs, the special cases, and what the legal work costs. It describes the general rules. How they apply to one sale depends on the contract and on the people involved, which is a question for the lawyers acting in it.

Ministry of Law, press release and frequently asked questions on the measures in force since 1 August 2011.

What changed on 1 August 2011

The Ministry of Law's press release on the measures says that from 1 August 2011 lawyers are prohibited from receiving and holding conveyancing money unless it is deposited in one of three ways: in a conveyancing account opened with an appointed bank, with the Singapore Academy of Law under its Conveyancing Money Service, or in an escrow account opened jointly by the lawyers acting for each party.

The ministry gives one purpose for the change: to give clients' money in conveyancing transactions a higher standard of protection. The Council for Estate Agencies, in its practice guidelines on options to purchase, places the safeguards in an amending Act of 2011, the Conveyancing and Law of Property (Conveyancing) Rules 2011 and the Singapore Academy of Law (Conveyancing Money) Rules 2011.

The prohibition carries a criminal penalty. According to the ministry, a lawyer who breaches it may be fined up to S$50,000, imprisoned for up to three years, or both, and may also face disciplinary proceedings under the Legal Profession Act. The rule is addressed to lawyers, but it shapes what everyone else in the sale does: the buyer writing the cheque, the seller choosing a stakeholder, and the salesperson preparing the option.

What counts as conveyancing money

The rules bite only on conveyancing money, so the first question is what falls inside the term. The ministry's frequently asked questions give the working answers. The deposit paid when an option is exercised and the balance of the purchase price are the obvious cases. Stamp duty is included too, with a threshold for leases: the full stamp duty on a transfer of property counts, while duty on a lease, licence or tenancy counts only when it is S$5,000 or more. A lease whose duty comes to S$4,800 therefore sits outside the term, and one whose duty comes to exactly S$5,000 sits inside it.

The same document says money payable when a tenancy is granted or surrendered, deposits included, is conveyancing money. So are penalties, insurance premiums, valuation fees and clawed-back legal subsidies when they form part of a loan repayment.

Some money a law firm handles in a sale is not conveyancing money, and the table below sorts the main items.

Two lines of that table deserve a word. The float is a small sum, up to S$5,000, that a firm may keep in its ordinary client account to meet the incidental costs of completion. The ministry's document says every disbursement from it must be documented and that anything left over belongs to the client. For a collective sale it describes a different arrangement, a float of S$2,000 per property capped at S$200,000 across the sale.

The last line concerns what the document calls anticipatory money: funds a buyer sends to a lawyer before any property has been identified. Lawyers may not hold it. The buyer keeps it in their own account until there is a property to buy.

Three places the money may sit

The first route is the one most buyers meet. A law firm opens a conveyancing account, which the ministry says can only be opened with an appointed bank. Its 2011 press release names five: Bank of China, DBS Bank, Oversea-Chinese Banking Corporation, The Bank of East Asia and United Overseas Bank. The money in such an account cannot be withdrawn on the firm's signature alone, which is the heart of the protection and the subject of a later section.

The second route takes the money out of the law firms' hands. Under its Conveyancing Money Service, the Singapore Academy of Law holds the money itself. The Council for Estate Agencies' practice guidelines describe this as the choice for parties who do not want to deposit money with their lawyers; the lawyer makes the arrangement and the payment is made out to the Academy.

The third route is an escrow account opened jointly by the buyer's lawyer and the seller's lawyer. The council's guidelines say such escrow agreements are mainly used for complex transactions.

For the option deposit in particular, the ministry's document says the measures do not limit who may hold it beyond those routes: the seller's lawyer's conveyancing account, a joint escrow account with the other side's lawyer, or the Academy's service.

The suffix that belongs on the cheque

A law firm has more than one bank account, and a cheque made out simply to the firm does not say which one it is meant for. The ministry settled that with a naming rule. Cheques, cashier's orders and bank drafts for conveyancing money that a law firm will hold must be made payable to the name of the firm followed by the suffix "-CVY". The Council for Estate Agencies repeats the point in its checklist for buyers of completed private homes: a buyer paying conveyancing money to the seller's law firm by cheque adds the suffix to the payee name.

The suffix applies to payments to a law firm. Money going to the Academy follows a different rule, set out below: the payee is the Academy itself, with no suffix.

For salespersons, the council's practice guidelines add a duty of care around the payment itself. Salespersons on both sides are expected to do due diligence on option money and deposits, including checking the details on the cheque, such as the name, the date and the amount.

Two signatures to move the money out

Paying in is the simple half. The protection lies in how the money leaves. The ministry's frequently asked questions say withdrawals from a conveyancing account need two-party authorisation. The Council for Estate Agencies' guidelines put it in practical terms: the second authorisation usually comes from the other party's lawyer.

The counter-signing lawyer is not there to approve the deal. According to the ministry's document, that lawyer checks that the payees and the amounts match the client's instructions. Any lawyer at the counter-signing firm may do it, provided they have practised in Singapore for three years or more in aggregate.

The mechanics are electronic. The ministry's press release says the Singapore Land Authority set up an electronic Payment Instructions service, known as ePI, on which lawyers initiate and counter-sign payment instructions, signing digitally with a personal Netrust token. The appointed banks and the Academy then retrieve the instructions and process them.

What if the second lawyer will not sign? The ministry's document says either party can refer a refusal to counter-sign to adjudication under a Law Society scheme, and the adjudicator decides whether the counter-signature should be given. The Academy's guidance notes say the same of disputes over money it holds.

The document also deals with last-minute changes. Completion figures often move in the final days. A change requires a variation form submitted before the cut-off; a typing error cannot be corrected by amending a form by hand. Same-day turnaround is pledged for urgent cases, subject to cut-off times. When an instruction is marked as the final payment, the bank can close the transaction, and any balance goes to the payee category that usually means the client.

When the Academy holds the deposit

The Academy's service is described in its Guidance Notes 1/2024, dated 31 December 2023 and in effect from 2 January 2024. They distinguish two kinds of money. The first is the stakeholding deposit, which the notes describe as the option deposit, usually 4 to 9 per cent of the purchase price less the option fee. The second is other conveyancing money, such as the balance of the purchase price, goods and services tax, and stamp duties.

As a worked example of that range, and nothing more: on an assumed purchase price of S$1,500,000, 4 per cent is S$60,000 and 9 per cent is S$135,000. The actual deposit in any sale is whatever the option says.

The Academy cannot be chosen by one side alone. For a stakeholding deposit, the notes say both purchaser and vendor must appoint it, by inserting the recommended stakeholding clause in the option to purchase or the sale and purchase agreement, before any deposit is paid in. Payment is by cheque or cashier's order payable to "Singapore Academy of Law", or by electronic transfer, accompanied by a pay-in form submitted no later than the day of the deposit. The notes ask for the money to be paid in at least 14 days before the Academy has to pay any of it out: a deposit needed on day 30 of a timetable is paid in by day 16.

The service has limits. The notes exclude sales governed by the Housing Developers Rules and by the executive condominium rules, collective sales of two or more properties, and money relating to refinancing, tenancy agreements or CPF.

There is a fee. The notes give a normal service fee of S$163.50 inclusive of goods and services tax, paid when the pay-in form is submitted. For a stakeholding deposit the vendor pays it by default; for other money, the party who deposited it pays. An additional express service fee of S$109.00, also inclusive of the tax and charged on top of the normal fee, applies when pay-out instructions arrive less than three working days before the expected date of collection; it is payable when the cheque is collected.

The pay-out timetable is strict, and the table sets out the three services the notes describe.

Two features set the Academy apart from a bank account. It pays out by its own cheques; a cashier's order is used only for payment to the vendor's mortgagee bank, and the notes say it makes no electronic transfers for pay-outs. And all interest and other income earned on the money it holds belongs to the Academy, not to the buyer or the seller.

If the sale falls through, the money does not move by itself. The notes say the parties complete pay-out forms to refund it, which again means both sides' lawyers signing.

Buyers without a lawyer, and one firm for both sides

The two-signature design assumes two law firms. The ministry's frequently asked questions cover the cases where there are not two.

A buyer who has not yet appointed a lawyer may still pay the deposit into the seller's lawyer's conveyancing account. In that case, the document says, the seller's lawyer names the buyer personally as counter-signatory, so that the money cannot leave without the buyer's agreement. Once the buyer appoints a lawyer, a change of counter-signatory form transfers the role.

One firm acting for both buyer and seller is the harder case. If that firm held the money, there would be nobody independent to counter-sign, and the document says the firm generally cannot hold it. It lists exceptions, including pure gifts and cases where the Housing and Development Board or the CPF Board acts as counter-signatory. In refinancing or redemption work, the same firm may act for all parties, but the money is expected to move directly between them and not through a conveyancing account. Where money is deposited by mistake, the appointed bank can reverse the entry.

CPF savings, HDB and homes still being built

Many purchases in Singapore are paid partly from the buyer's Central Provident Fund savings, and that money follows its own track. The ministry's document says CPF money is released to a separate conveyancing (CPF) account held by a law firm on the CPF Board's panel. Where the CPF savings are used only for monthly instalments, the board pays the mortgagee bank directly, and no law firm holds the money at all.

The CPF Board's own guide to housing expenses, published on 28 April 2026, draws a line that matters at the very start of a purchase: option fees cannot be paid with CPF savings, while Ordinary Account savings can pay stamp duty and legal fees in full.

A home bought from a developer before it is built is different again. The ministry's document says buyers of uncompleted property usually pay the developer directly into the project account, so the progress payments do not pass through a lawyer's conveyancing account. If a buyer does route a payment through a conveyancing account, the developer's lawyer counter-signs. This is also why the Academy's service leaves out sales under the Housing Developers Rules.

What the salesperson must explain

Property agents do not hold conveyancing money, but they often prepare the document that decides where it goes. The Council for Estate Agencies' Practice Guidelines 1-2021, version 3.0, in effect from 24 February 2021, set out what is expected when an agent acting for the vendor helps prepare an option to purchase or a sale and purchase agreement and the vendor wants the deposit held by a stakeholder.

The agent must make sure the agreement contains the necessary provisions, explain that the vendor can specify whether the deposit is held by the vendor's lawyer or by the Academy as stakeholder, and ask the vendor to choose and delete the clause that does not apply. The council's checklist for sellers of completed private homes makes the same point from the seller's side: the option should specify that the option deposit goes to the seller's lawyer's conveyancing account or to the Academy.

The guidelines also state, in a separate paragraph, that agents and salespersons must not abet any offence under the Conveyancing and Law of Property Act or the conveyancing rules. The duty on the lawyer and the duty on the agent thus point the same way: towards one of the three routes.

The cheque is written once. Which account it reaches is decided earlier, by a clause in the option and a suffix on the payee line.

What the legal work costs

None of the sources read for this guide sets an official fee scale for private conveyancing lawyers. The CPF Board's April 2026 guide gives an estimate: a private lawyer for a purchase with a bank loan costs about S$2,500 to S$3,000 on average, payable in cash or from CPF savings.

Where the Housing and Development Board acts in the conveyance, the same guide gives a scale: S$0.90 per S$1,000 for the first S$30,000, S$0.72 per S$1,000 for the next S$30,000, and S$0.60 per S$1,000 for the remainder. As a worked example, applied to an assumed amount of S$500,000, the first band gives 30 times S$0.90, or S$27.00; the second gives 30 times S$0.72, or S$21.60; the remaining S$440,000 gives 440 times S$0.60, or S$264.00. The three add up to S$312.60. The example shows only how the bands stack; it leaves aside any rounding, minimum or tax that the board may apply, which the guide as read does not detail.

The holding of the money has its own charges, separate from the lawyer's fee. The ministry's 2011 document put the appointed banks' and the Academy's fees at between nothing, during a free first year from 1 August 2011, and S$150 before goods and services tax per property transaction. The Academy's current figure is the S$163.50 given above. The document adds that CPF savings can be used to pay an appointed bank's transaction costs.

What the sources leave open

Three points could not be settled from the documents read for this guide, and a reader relying on them would want to check each.

The list of five appointed banks comes from the Ministry of Law's 2011 press release, on a page last updated on 25 November 2012. Whether the list is unchanged in October 2026 was not confirmed. The same goes for the banks' fees: the range of nothing to S$150 dates from 2011, and only the Academy's fee has a recent source.

The text of the Conveyancing and Law of Property (Conveyancing) Rules 2011 itself was not read. Everything above rests on how the ministry, the Academy and the Council for Estate Agencies describe those rules, not on the rules' own wording.

Lastly, the Academy's notes say plainly that interest on money it holds belongs to the Academy. The documents read do not say what happens to interest on money in a law firm's conveyancing account at an appointed bank, so this guide makes no statement on it.

Kooky, from Shaka

Kooky edits Agents Estate and builds Shaka, the payment router he made for real estate professionals. One payment comes in, and every agent, agency and party in the deal receives their signed share on closing date.

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