September 2025
For many property managers, the day-to-day responsibilities of tenant move-ins can feel like a blur — leasing paperwork, keys, inspections, and of course security deposits. But here's the thing: How and when you handle those deposits is one of the most important compliance obligations you have.
Under
Oregon Administrative Rule (OAR) 863-025-0065(4), you have
5 banking days to deposit tenant security deposits into the security deposit account. That's not a target — it's a deadline. Holding on to funds, even if it's “just for a few days,” is in violation of the Oregon Real Estate Agency’s administrative rules.
Often, tenants make a single payment that includes the security deposit, rent, and other fees.
OAR 863-025-0030(2) allows a property manager to deposit such combined payments into a client's trust account or owner account. However, in this instance, the portion of the funds constituting security deposits must be transferred and deposited into the security deposit account within
3 banking days.
If you wait until the end of the month to move security deposits, you are most likely out of compliance and not acting in a fiduciary manner in all matters relating to trust funds as required under
Oregon Revised Statute 696.890(4)(e). The timing requirements are strict, and failing to meet them is one of the most common trust account violations.
To avoid this possible violation, property managers should have internal procedures in place to track when security deposits are received as part of a larger payment and to ensure timely transfer into the correct account. A clear, consistent process not only keeps you in compliance but also protects your clients and reinforces trust in your management practices.