No – however if you grant a new ‘’ on or after 1st June 2019, you are deemed to be ‘taking a payment’ for the for the new tenancy and any amount exceeding 5 weeks rent becomes a prohibited payment if it is not repaid within 28 days. (Superstrike Ltd v Rodrigues  EWCA Civ 669). The guidance on the Tenant Fees Act 2019 says:
Q: If a tenant paid a
A: No. Landlords and letting agents are not obliged to immediately refund part of a that is above the cap but was paid before 1 June 2019.
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