Security Deposits When Loom Does Not Hold Leasing Trust Funds
Review landlord-direct payment, processor access, deposit records, approved PM accounts, and California security-deposit sources.
Sources checked October 29, 2026 · California guidance · Loom broker: Kayla Jane Bramante, CA DRE #02017652
Short Answer
Start with who receives and controls the money. A direct-to-landlord route can be reviewed when neither the operator nor Loom receives or controls the funds. A processor is not automatically an exemption, and a supervised property-management trust account is a separate, selectively approved arrangement.
A Direct-to-Landlord Payment Route to Review
This is a proposed route for review, not approval of any particular account or platform. Security deposits remain subject to tenant-protection rules; payment to a landlord does not turn the deposit into earned income or remove refund/accounting obligations.
The lease should identify the responsible holder and payment instructions. Review state rules, deductions, documentation, timing and any local requirements with appropriate legal support. Residential and commercial deposits are governed by different statutes.
Tenant pays the landlord using the approved instructions
Funds go directly to the landlord; operator and Loom have no receipt or control
Landlord retains deposit accounting and return obligations; file retains the agreement and relevant payment evidence
Loom reviews these facts before accepting a funds flow. Do not assume an automatic payout, pass-through label or software ledger eliminates trust-fund duties. Escalate an unintended receipt or account change promptly so the responsible broker can direct the appropriate response.
Who owns each bank or processor account, and in whose name is it titled?
Can the operator hold, delay, refund, redirect, withdraw or split a payment?
Are rent, fees, deposits and reserves mixed before payout?
Who authorizes disbursements, keeps beneficiary records, investigates shortages and completes reconciliations?
What happens if funds arrive in the wrong account or access permissions change?
Loom does not receive, hold, deposit or disburse leasing or sales trust funds. For property management only, a client may separately request account-level review. Written acceptance is required before the $100-per-account monthly oversight service applies; it is not a default banking or custody service.
For an approved account, confirm the licensed entity, trust designation, DO/broker authority, permitted signers and written authorizations with the bank and responsible broker. Bookkeeping can be delegated, but statutory broker responsibility is not eliminated.
RE 4522: control record for trust funds received and paid out through a trust bank account.
RE 4523: separate beneficiary or transaction record.
RE 4524: funds received but not placed in the broker trust account, where applicable.
RE 4525: separate property-managed record; RE 540: broker self-evaluation.
Maintain required reconciliations and supporting records for the approved workflow. A blank form or portal upload does not itself establish a compliant system.
Can I open a leasing trust account through Loom for deposits?
Loom does not provide leasing or sales trust-fund custody. Discuss a landlord-direct route or another lawful arrangement appropriate to the actual operations. A separately approved PM account is a different scope.
Does routing deposits through an app remove trust-fund requirements?
No automatic exemption follows from using an app. Actual receipt, control, account ownership and disbursement authority must be reviewed.
Can a landlord simply treat a security deposit as rent?
A deposit’s purpose and applicable law determine how it must be handled. Review the lease and the appropriate residential or nonresidential statute rather than treating the deposit as earned income.
Review Your Proposed Scope
Send the entity type, license status, activities, locations, payment flow and intended start date.
General information and Loom service policies are identified separately. Current law, property-specific facts and the written agreement control. Entity, tax, insurance, housing-law and filing decisions belong with the appropriate qualified professionals and agencies.