Essential Sourcing Compliance for the  Deal Sourcer, Deal Packager and Investor


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I realised no one really talked about the legislation around property sourcing and deal packaging, it was like a little dark secret sitting in the corner

Tina Walsh began her career in the police force and started investing in property in 2005, a chance remark led her into the world of deal packaging and she now combines her passion for property sourcing with everything compliance-related.

She is an expert on the compliance requirements for deal sourcers and deal packagers and in this episode, she shares the essential steps that deal packagers and sourcers must take when they start out and the key questions that any investor should ask.

Tina explains clearly the steps that must be taken to ensure compliance and why it’s important for both deal sourcers, deal packagers and investors to be on the right side of the law.


The Sourcer

  • As a sourcer you’ve started your business and set up a bank account you now need;

Insurance – professional indemnity insurance this covers you for your professional services.

  • Not all independent insurers understand what deal packaging is you must ensure you are working with a broker who has a bespoke policy for you and understands property sourcing

Register with one of 2 ombudsmen

  • Register with either the TPO or PRS. The TPO is a not for profit organisation and the PRS is a more modern entity and is run by property professionals for profit. The services they provide are very similar.

Register for data protection supervision with the ICO – as a property sourcer you gain a huge amount of information on your clients.  If you are handing someone personal details they should be treated with respect

Register for anti-money laundering supervision with HMRC

  • You must carry out due diligence gaining proof of ID, address and that they have the funds available. You must also ask about the source of the funds.
  • You are expected to do some research and have an audit trail for the source of funds
  • Registering for supervision isn’t the end of compliance it’s just the beginning, there are codes of conduct to follow and minimum standards
  • Below the registration are the policies, standards risk assessment and training all of which must be recorded and provable as standards within your business.

The Investor

  • You should be asking
  • Do they have professional indemnity insurance and what is the level?
  • Are they registered with an ombudsman?  it’s a legal requirement
  • Are they registered with the ICO?
  • Are they registered for anti-money laundering?
  • Check that the registration numbers supplied are accurate, make sure you do your due diligence.
  • If something has gone wrong being registered with the ombudsman is key, as part of their code of conduct the deal packager is required to have an in-house complaints policy.


‘It’s key you check there is an in-house complaints policy’

‘Someone may have inherited cash and this can be proved through the solicitor’

‘Just because as a deal sourcer you don’t have a shop front you shouldn’t think HMRC won’t come knocking on your front door’


The Serviced Accommodation Property Podcast


Property Sourcing Compliance Facebook


Your host Kevin Poneskis enjoys public speaking, travelling, exercising and keeping fit. He also enjoys working with a charity called STOLL which provides accommodation and training for homeless veterans.

Kevin was in the British Army serving 24 years, mostly in a Commando unit and retired at the rank of Regimental Sergeant Major. He left the Army in 2011 and became a full-time property investor. During most of his Army career, Kevin was investing in property and has been a property investor now for over 27 years.


35 episodes