A Holding Deposit and a Tenancy Deposit are 2 different things. A Tencncy does not commence until the tenant takes possession, therefore a tenancy deposit can not exist before the commencement of the tenancy.
The current law is that a Holding Deposit does not need protection, once it becomes a Tenancy Deposit it needs protecting within 14 days.
The Localism Act will extend that to 30 days - but the penalties for non-compliance will change too.
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