Trust funds are not the broker's money
Earnest money, security deposits and association funds belong to someone else while the broker holds them. Georgia's timing, separation and disbursement rules follow from that, and the exam tests the clocks.
Two different deposit clocks
Contract clock. GAR F201 §B.7 requires the Holder to deposit the earnest money not later than five banking days after the Binding Agreement Date, or five banking days after actual receipt if later.
Statutory clock. O.C.G.A. 43-40-20(a) excuses a broker who accepts no trust funds from keeping an account, but requires that broker to open the designated trust or escrow account within one business day of receipt.
Do not swap them: one business day is account-opening, not the deposit deadline; ten calendar days is not five banking days. Rule 520-1-.08(1)(a) separately gives one month to notify GREC of the opening. Parking the check in the firm operating account is commingling, an unfair trade practice under 43-40-25(b)(4), and GREC never holds funds for safekeeping.
No commission from trust funds until the deal is over
O.C.G.A. 43-40-20(e) says a broker is not entitled to any part of the earnest money, security deposit or other trust funds as commission until the transaction has been consummated or terminated.
Expiration of contingencies is not that event. The listing client's oral approval will not do, because the seller alone cannot authorize disbursement of funds in which the buyer has an interest. Documenting the amount in the records is recordkeeping, not entitlement.
Categories stay apart
Rule 520-1-.08(4) requires property management and community association funds to be held in trust accounts separate from sales escrow. Pooling everything into one designated escrow account with per-party ledgers is the mixing the rule forbids, and holding association funds in the operating account as fee income is commingling.
Security deposits held by a broker must be clearly identified and credited to the tenant, with the balance always equal to the deposits held. A salesperson may not hold them personally: 43-40-25(b)(23) requires funds to be placed in the broker's custody as soon after receipt as practicable.