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Exam distinction · State Laws and Rules

Commingling Versus Conversion

Commingling is improper mixing of a broker's money with trust funds. Conversion is unauthorized use or control of another person's money or property. A single act can involve both, but conversion is the more serious use-based classification. Georgia permits only limited, clearly identified broker funds in a trust account for purposes stated in Rule 520-1-.08.

Facts checked against the current PSI Candidate Information Bulletin and GREC sources. Editorial standards.

What is the exam-ready distinction?

Commingling is improper mixing of a broker's money with trust funds. Conversion is unauthorized use or control of another person's money or property. A single act can involve both, but conversion is the more serious use-based classification. Georgia permits only limited, clearly identified broker funds in a trust account for purposes stated in Rule 520-1-.08.
Official syllabus mapping for Commingling Versus Conversion
Official syllabus topicGeorgia Laws and Rules: Trust Accounts, Commingling, Conversion, and Broker Control
Official PSI areaState Laws and Rules
Published weight16 of the 52 Georgia questions
Source editionPSI Georgia Candidate Information Bulletin dated July 1, 2026

The Rule

PSI publishes a weight for the complete official area, not a guaranteed count for this individual comparison. Use the source, document, actor, event, and timing stated in the question before applying a memorized definition.

Side-by-side comparison

Read across each row. The terms are deliberately compared on identical dimensions so the difference remains clear when the exam hides the vocabulary inside a scenario.

Comparison of Commingling, Conversion
Decision dimensionComminglingConversion
ConductImproperly mixes broker or firm money with money held for othersUnauthorized use or control of money or property belonging to another
HarmDestroys required separation and accounting even without proven spendingDeprives the owner of authorized control or use
ExampleDepositing operating revenue into a client trust account outside permitted exceptionsUsing earnest money to pay firm payroll
Georgia exception cautionRule 520-1-.08 permits clearly identified broker funds for specified minimum-balance, charge, and earned-commission purposesThose narrow accounting permissions do not authorize personal use of trust funds

Decision rule

Trace whose money it is, where it was deposited, how the ledger identifies it, whether a rule permits the broker funds, and whether anyone used or disbursed trust money without authority.

Georgia-specific distinction

GREC Rule 520-1-.08 requires designated accounts, prompt broker custody and deposit, detailed accounting, authorized disbursement, and monthly reconciliation. It narrowly permits identified broker funds for minimum balances, account charges, and properly accounted earned commissions.

Worked example

Scenario. A Georgia broker withdraws a buyer's earnest money from the trust account to cover the firm's payroll, intending to replace it next week.

Reason it through. The buyer's funds were used for an unauthorized firm purpose. An intention to repay does not turn the use into an authorized disbursement.

Answer. The conduct is conversion and also creates trust-account and commingling concerns.

Common exam traps

  • Requiring permanent theft before finding conversion
  • Calling every permitted service-charge balance commingling
  • Assuming intent to repay cures unauthorized use
  • Ignoring the ledger and monthly reconciliation

Original practice questions with detailed explanations

These are original instructional questions mapped to the July 1, 2026 PSI outline. They are not copied from PSI or any live examination. Choose an answer before opening the explanation.

Question 1

A Georgia broker takes a buyer's earnest money out of the trust account to cover the firm's payroll, planning to put it back next week. How is this best classified?

  1. A. Only commingling, since the money stayed within the firm
  2. B. A permitted short-term advance if it is repaid on time
  3. C. A bookkeeping delay that monthly reconciliation will fix
  4. D. Conversion, because trust money was used without authority
Show answer and explanation →

Answer: D. Conversion, because trust money was used without authority

Conversion is unauthorized use of another person's money, and paying payroll with a buyer's earnest money is exactly that. Planning to repay does not make the use authorized. The commingling answer understates the problem, since conversion is the more serious, use-based classification.

Question 2

A broker deposits the firm's own operating revenue into the trust account that holds clients' earnest money. None of the money is spent. What has occurred?

  1. A. Commingling, because firm money was mixed with trust funds
  2. B. Conversion, because the broker controls the trust account
  3. C. No violation, because none of the trust money was spent
  4. D. A permitted deposit, because brokers may add their own funds
Show answer and explanation →

Answer: A. Commingling, because firm money was mixed with trust funds

Commingling is improperly mixing a broker's own money with money held for others, and it is a violation even if nothing is spent. Operating revenue is not one of the narrow broker-fund uses that GREC's trust account rule permits. Deciding there is no violation because nothing was spent is the trap, since keeping the money separate is itself the duty.

Question 3

Which deposit of a broker's own money into a Georgia trust account can be permitted when it is clearly identified in the records?

  1. A. Personal savings kept there to earn a better interest rate
  2. B. Funds to meet the account's minimum balance or its charges
  3. C. Operating revenue parked there until the firm's bills are paid
  4. D. Money the broker plans to lend to agents as commission advances
Show answer and explanation →

Answer: B. Funds to meet the account's minimum balance or its charges

GREC's trust account rule narrowly allows identified broker funds for minimum balances, account charges, and properly accounted earned commissions. Covering the account's minimum or its bank charges fits that exception. Personal savings and operating money are commingling no matter how carefully they are labeled.

Ready to move on?

You have this distinction down when all of these are true.

  • Define every compared term without using the other term as the definition.
  • Rebuild the comparison table from memory.
  • State the decision rule and Georgia distinction without notes.
  • Solve the worked example after changing one key fact.
  • Explain the rule or fact that makes each distractor wrong.
  • Answer all three original questions correctly in mixed practice on a later day.

Recommended next lesson

Continue with Georgia Attorney Closing Versus Title or Escrow Closing. Earnest money handling ends at closing, and the next article explains who runs a Georgia closing, a Georgia attorney, and where filling in a form stops and practicing law begins.

Return to the complete exam-concept library or the State Laws and Rules hub.

Commingling Versus Conversion questions

Facts checked against the current PSI Candidate Information Bulletin and GREC sources. Editorial standards.

Is Commingling Versus Conversion on the Georgia real estate exam?

Yes. It maps to the official State Laws and Rules area, which represents 16 of the 52 Georgia questions. PSI does not publish a guaranteed question count for this individual distinction.

What is the fastest way to distinguish Commingling Versus Conversion?

Trace whose money it is, where it was deposited, how the ledger identifies it, whether a rule permits the broker funds, and whether anyone used or disbursed trust money without authority.

What Georgia-specific point should I remember?

GREC Rule 520-1-.08 requires designated accounts, prompt broker custody and deposit, detailed accounting, authorized disbursement, and monthly reconciliation. It narrowly permits identified broker funds for minimum balances, account charges, and properly accounted earned commissions.

How should I study similar-looking real estate terms?

Compare the terms across the same dimensions, classify the key fact before reading the choices, explain why each distractor belongs to a different concept, and retest the distinction later in mixed practice.