Platform implementation guide
If you’re moving your customer’s money, you likely already know about some of the compliance requirements. This guide addresses how to implement a few of these requirements.
You’ll need to:
- Know whose money you’re moving.
- Keep track of what money belongs to each of your customers.
- Share these details with us.
Setting up your accounts correctly makes this easier. First you’ll need to determine what account structure is right for you and who will legally own the accounts.
Typically we recommend spinning up an individual account for each of your customers. This prevents the need to keep a separate ledger. It also gives you maximum flexibility for account ownership. Account creation is synchronous. There is no limit on the number of accounts you can create.
Alternatively you can have one commingled account. You’ll need to keep track of whose funds are whose. In either structure, you can also create unique account numbers. These are particularly useful for tracking inbound payments.
Every account is owned by an entity. When moving money on behalf of customers, there are three common options:
- Option 1: Accounts are owned by your own entity.
- Option 2: Accounts are owned by the bank’s entity for the benefit (FBO) of your customers.
- Option 3: Entities are created for individual customers, each of which owns their own account.
Options 1 and 2 work with either account structure. Option 3 only works if you create individual accounts. In order for you to own the account, option 1, you’ll need to ensure you have the appropriate regulatory permissions. You’ll definitely want to chat with your legal team on this.
We typically recommend option 3, though there are lots of factors to consider here. We’re always happy to think through them with you.
|Ownership||Individual Accounts||Commingled Accounts|
|You own accounts||Y||Y|
|Accounts are owned by the bank for the benefit (FBO) of your customers||Y||Y|
|Individual customers own accounts||Y||N|
Okay! Now that we know how you’ll be structuring accounts and ownership, let’s talk implementation.
Who are your customers
We’ll keep track of your customers using the information you submit to the
entity API. Regardless of the legal account owners, we’ll need all of the required information for each of your customers.
|You own accounts||Each |
|Accounts are owned by the bank for the benefit (FBO) of your customers||Each |
|Individual customers own accounts||Each |
Customer Information Program
You’ll be responsible for verifying the identity of your customers through your own Customer Information Program. We’ll collect the data you receive from any identity verification provider using the
supplemental_documents parameter on Entity creation. This should include
ids of one or more Files created via the File API. These files can be unstructured content: perhaps a PDF containing an identity document, or a JSON blob returned by the identity provider’s API.
Tracking customer balances
We’ll also keep track of how much money each of your customers is holding. You can either keep track by creating individual customer accounts or by submitting your ledger balances at the end of each day.
|Individual customer accounts||If your individual customers own their accounts, you’re done! If you’re holding your customer money in your own name or in the bank’s name, you’ll pass the |
|Commingled accounts||You’ll need to pass the end of day balances and the associated |
If you have any questions don’t hesitate to reach out to email@example.com.