As part of its continuing review of referral fee arrangements, the Council for Licensed Conveyancers (CLC) is inviting licence holders and consumers to share their views in two new surveys.
In June, the regulator published an interim report which found referral arrangements can play a legitimate role in conveyancing and help consumers to access services conveniently, provided they operate clearly, consistently and in the interests of consumers.
Although it found no evidence to support a ban or cap on referral arrangements, it did put forward a series of recommendations aimed at strengthening transparency and consumer protection.
Recommendations included earlier and clearer disclosure of referral arrangements so consumers can make informed choices at the outset, strengthening expectations around written agreements and record keeping, working with the property sector and consumer bodies to improve awareness of disclosure responsibilities, and targeted monitoring to assess how effectively any changes are operating in practice.
The CLC now wants to hear what licence holders have to say about the recommendations, as well as their views on current guidance and their own experience of referral arrangements. The insight will “help paint a picture of what’s happening in practice, and what’s working well and what isn’t, in order to develop clear, proportionate and practical guidance”, the CLC said in a statement.
In July 2025 the CLC announced it would undertake a thematic review into referral fees in the wake of the BBC Panorama documentary on conditional selling – the first review in 13 years.
The regulator also defended its position last month after a position paper released by the Legal Services Consumer Panel (LSCP) singled the CLC out for criticism in a report that called for the Legal Services Board and the Ministry of Justice to take immediate action to replace the current system of eight legal regulators with a single independent body.
The LSCP said the regulator should have taken action to halt the practices identified in the BBC documentary instead of waiting for a television programme. In response, CLC CEO Sheila Kumar said the LSCP has misrepresented the CLC, pointing out that the practices under question were from estate agents, not conveyancers, and adding it was the only regulator to respond by launching its review and proactively respond to “market intelligence”.
The survey of licence fee holders is open until midnight on Friday 25th September. All responses will remain strictly anonymous.
A separate consumer survey seeking the views of home movers when it comes to referral arrangements also closes on 25th September.
2 responses
Good to see the CLC asking practices what’s actually happening on the ground before firming up the rules. Referral arrangements sit right at the point where a client decides who to trust in the chain — which is also exactly where fraudsters try to insert themselves, posing as the “recommended” contact. If you’re CLC-regulated, the survey closes 25 September; ten minutes giving your view now beats living with a rule you didn’t shape later.
The nuance people miss in the TPMA conversation is that it changes where the money sits, not where the responsibility sits — Rule 11 still puts the duty squarely on the firm to make sure clients understand what’s happening with their funds. And since so much completion-funds fraud starts with a confused client unsure whose bank details to trust, anything that makes the money journey clearer to the client is worth taking seriously on security grounds alone.