comptabilité des notaires

09:06 Dec 14, 2018

French to English translations [PRO]
Bus/Financial - Real Estate / Credit Agreement for the purchase of a Building

French term or phrase: comptabilité des notaires

"Les commissions dues à la Date de Signature sont payées par l'intermédiaire de la ***comptabilité des notaires***."

Is this a specific account? A deposit? Any ideas?

elizabeth_med KudoZ activity Questions: 392 (10 open) (16 without valid answers) (3 closed without grading) Answers: 1 France
Local time: 07:53

Summary of answers provided

4 +1

notaries' account

B D Finch

3 +1

notaires' accounting

Tony M

Discussion entries: 8

Daryo

United Kingdom

@ Eliza Hall

12:06 Dec 16, 2018

Agree. Although "no one else is qualified" more accurately would be "no one else is authorised" - nowadays at least.

I remember reading years ago a very interesting article about the underhand ways French "notaires" managed to snub the other legal "tribes" and clinch this legal monopoly on conveyancing decades ago. (just a digression)

I realise now that my formulation was ambiguous.

When I said "who in his right mind would want such a person involved in any serious business involving real estate in France" I had in mind "any person who thinks that a French notaire is the same as a US notary, just because it's similarly sounding"

Eliza Hall

United States

@ Daryo

14:12 Dec 15, 2018

You asked, "who in his right mind would want such a person involved in any serious business involving real estate in France, what would then be an appropriate translation?"

In France you would want a notaire, and actually I think that's who you have to use for real estate -- no one else is qualified. But yes, you would never ever want a US notary anywhere near a real estate transaction, except if you needed someone's signature to be notarized (authenticated -- i.e. the notary checked the person's ID to confirm who they were, and then watched them sign).

So if the original text is talking about a notaire in a French real estate transaction, I would either translate it as "French real estate transaction attorney" (or real estate counsel, or something like that), or leave it in French, italicized, with the explanatory translation in parentheses.

If it's talking about notaires more generally, as Elizabeth's text may be, I would definitely use the italicized French word + explanation in parentheses approach for the first instance of the word, and then just italicized "notaires" for all later instances.

B D Finch

France

Notaries UK and US

10:54 Dec 15, 2018

There is a problem, when translating for an international or undefined readership, in that a notary in England and Wales is a qualified professional, while a notary in the US is a (very slightly) glorified clerical worker.

Daryo

United Kingdom

@ Eliza Hall

23:31 Dec 14, 2018

OK - "notary" would be seriously misleading for someone in UK or US who hasn't got a clue about the French legal system.

Leaving aside a quite natural question to ask: who in his right mind would want such a person involved in any serious business involving real estate in France, what would then be an appropriate translation?

Tony M

France

@ Eliza

21:31 Dec 14, 2018

And not just in the US either! The situation is not so very different in the UK, where a notary has a quite different role and does not deal with house conveyancing, for example.

Eliza Hall

United States

Notaire does not mean notary

18:49 Dec 14, 2018

In France a notaire is a type of lawyer. You can't become a notaire without a master's in law -- the same degree required to become a lawyer in France. You also have to do a two-year post-master's internship, take an exam (un concours), and swear an oath before the court. This is the same path every French lawyer follows, with differences due only to specialization (a future commercial litigator doesn't take the same concours or do the same internship as a future notaire). The same is true in the UK.

However, in the US a notary is just someone temporarily certified by the state to confirm the authenticity of signatures and of copied documents. That's all they can do. No post-high school education is required; some states don't even require a high school diploma.

Unless you're writing for a clearly and strictly British audience, it is a mistake to translate notaire by notary or vice-versa.

Compare:

Comment devenir notaire: https://www.lepetitjuriste.fr/conseils-et-orientation/commen...

How to become a notary in New York state:
https://www.dos.ny.gov/licensing/notary/notary.html

UK: https://www.frenchentree.com/french-property/law/notary-or-n...

elizabeth_med

France

ASKER

13:01 Dec 14, 2018

France.

Tony M

France

@ Asker: Context?

10:41 Dec 14, 2018

What country is this from? In France, there is a special secure account used with a different name, so it's important to know where this is from?

Answers

56 mins confidence:

peer agreement (net): +1

notaries' account

Explanation:
https://howtobuya.house/why-do-i-have-to-go-to-the-notary/
In Amsterdam the notary is a VIP. The purchase and sales agreement is signed at the office of a notary and also all money travels through the notaries account.

https://www.frenchentree.com/france.../do-i-need-to-open-a-f...
... have just started with the process of buying a French property. ... Wiring it to the Notaries' account from your UK bank is all you need to do.

B D Finch
France
Local time: 07:53
Specializes in field
Native speaker of: English
PRO pts in category: 271

Peer comments on this answer (and responses from the answerer)

agree

philgoddard: Accounts in the plural, presumably.

25 mins

-> Thanks phil. No, singular for "account", unless more than one firm of notaries is involved.

neutral

Tony M: Surely it's actually their "accounts dept.", which is the more usual meaning of 'compta'

5 hrs

-> That's what I originally thought, but smaller firms of notaires don't have accounts departments and a payment handled by the notaire must go through their account.

disagree

Eliza Hall: Given the massive difference between French notaires and US/UK notaries, I would never translate the one by the other.

8 hrs

-> You're right.

neutral

Daryo: technically all monies would transit trough the notaire's "client account" NOT notaire's own bank account.

13 hrs

-> True, but does that need to be spelled out?

agree

GILLES MEUNIER

3 days 2 hrs

-> Thanks Gilou

6 hrs confidence:

peer agreement (net): +1

notaires' accounting

Explanation:
When dealing with FR notaires, I always prefer to retain the FR term, in italics if possible to indicate that fact, as there is such a huge difference between the role of a notaire</> and a notary in EN-speaking countries.
It depends a bit why there are multiple notaires involved here, and also, to whom and for what this 'commission' is being paid?
I think what they are saying is that the purchaser (?) will pay the commission to the agent (?) via the notaires, instead of, say, directly. If nothing else, this should mean that all will be official and above board — ahem!

Tony M
France
Local time: 07:53
Specializes in field
Native speaker of:

English
PRO pts in category: 365

Peer comments on this answer (and responses from the answerer)

agree

Eliza Hall

2 hrs

-> Thanks, Eliza!

neutral

B D Finch: Agree with "notaires" being kept in French, but "accounting" seems gramatically wrong.

2 hrs

-> Thanks, B! It depends, of course, just how Asker works it into their sentence; 'accounts department' might do instead, but anything to avoid suggesting a '(bank) account' or even 'through their books'.

neutral

Daryo: although the ST literally says that, "accounting" here doesn't sound right - money would be going through the notaire's "client account" (=the key point), who is doing the accounting for these transaction is secondary.

7 hrs

-> Yes, but we mustn't over-interpret on the basis of our inside knowledge; we don't know which actual account it will be, all we know is that it is passing through the notaire's financial 'hands'

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