Reviewed by Casa Academy and updated July 29, 2026 using the current DBPR checklist and Pearson VUE scheduling guidance.

Commingling

Commingling is the illegal mixing of a client's trust or escrow funds with a broker's personal or operating account, or with funds belonging to other clients, instead of maintaining segregated trust accounts as required by license law.

Exam context

Flag any scenario where earnest money lands in a sales associate's personal account or the broker's general operating fund. Correct answers cite segregated trust accounts and prompt deposit rules.

Why trust accounts exist

Earnest money, security deposits, and other client funds must be deposited promptly into a designated trust account and accounted for separately. Brokers may not use client money to cover office rent, payroll, or personal expenses even temporarily. State commissions audit trust records for shortages and delayed deposits.

Commingling vs conversion

Commingling is mixing funds; conversion is unauthorized use or theft of client money. Both violate license law and may trigger civil liability or criminal charges. Keeping earnest money in a personal checking account overnight is commingling even if the broker intends to transfer it later.

Examples

  • Earnest money deposit

    A buyer delivers a $5,000 earnest money check. The listing broker must deposit it into the brokerage trust account within the time state rules allow, not into the broker's personal savings.

  • Security deposit error

    A property manager places tenant security deposits in the owner's operating account mixed with rent income. This commingling violates typical residential trust fund statutes.

Keep studying

Related terms

Related resources

Sources