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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.

Account structure

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.

Account ownership

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.

OwnershipIndividual AccountsCommingled Accounts
You own accountsYY
Accounts are owned by the bank for the benefit (FBO) of your customersYY
Individual customers own accountsYN

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.

Account OwnershipImplementation
You own accountsEach account will be created under your corporate entity. You’ll create an informational entity for each of your customers using the relationship parameter on Post /entities.
Accounts are owned by the bank for the benefit (FBO) of your customersEach account will be created under the bank’s entity (which we’ll create for you) and held for the benefit of your customers. You’ll create an informational entity for each of your customers using the relationship parameter on Post /entities.
Individual customers own accountsEach account will be created under the relevant entity. You’ll create unaffiliated entities for each of these customers as these entities are not owned or controlled by you.

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.

Account StructureImplementation
Individual customer accountsIf 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 entity_id associated with the informational_entity on account creation.
Commingled accountsYou’ll need to pass the end of day balances and the associated entity_id for each of your customers to the bookkeeping API. The documentation for this API is currently gated. Please ping us for more details.

If you have any questions don’t hesitate to reach out to