FBO Accounts
SUBACCOUNT-US IB-SUBACCOUNT-US
Introduction
FBO Accounts are accounts opened and held in your platform’s name for the benefit of your users. FBO Accounts offer pass-through FDIC insurance if certain requirements are met.
We offer both FBO Deposit Accounts (SUB-ACCOUNT-US) and FBO Interest Bearing (Savings) Accounts (<<subAccount_interestBearingUS>>), and maintain the functionality of deposit (IC-DEPOSIT-US) or savings accounts (IB-DEPOSIT-US) while having fewer KYC requirements.
Because FBO Accounts keep the platform in the flow of funds, MSB or MTL registration (or an exemption) is usually required to use these accounts. Please keep in mind that remaining in the flow of funds also exposes the platform to additional risk.
Common Use Cases
- Platforms offering money transmission services that would like to ledger funds in a more organized way to one sole Clearing or Deposit account.
- All common use cases of custodial accounts if the platform has MSB or MTL registration (or an exemption) and wishes to collect less KYC.
Previous Steps
- Create user with KYC (recommended).
or - If user has been created already, then add required KYC.
Recommend User Creation and KYC Submission Flow
Please look at our KYC Overview for our suggested user creation and KYC addition process. Not following this process can lead to bad user experience and unnecessary efforts by the platform.
Next Steps
- If you open either an FBO Deposit Account or an FBO Interest Bearing (Savings) Account you can make transfers to and from the account and create account and routing numbers.
- If you are creating an FBO Deposit Account, you can also issue a debit card for the account.
KYC Requirements
FBO accounts have lower KYC requirements than comparable accounts. This is because the Platform is legally holding the funds and is consequently taking a greater share of the responsibility for those funds. Specific KYC requirements will vary by use case and nature of the user, but we will require the following KYC at the minimum:
Minimum KYC for Individuals
| Minimum KYC for Individuals | |
|---|---|
| Base Documentation | Name, Date of Birth, Address, Email (if unverified: 2FA), Phone Number (if unverified: 2FA). |
| Virtual Documents (Recommended but Not Required) | Social Security Number (SSN) with W-9 Verification. |
Minimum KYC Requirements for Businesses
To open a business FBO Account, you must supply the KYC of the table below as well as submitting a UBO form.
Minimum KYC for Beneficial Owners
We might require KYC from business beneficial owners (an individual owning 25% or more of the entity) depending on the use case.
For more information on the specific documents allowed for each KYC category and our verification process please refer to KYC Documentation and Verification.
Sub-Resources
FBO Account APIs
For FBO Deposit Accounts
For FBO Interest Bearing (Savings) Accounts
Legal Disclosures
Please make sure to check our General Legal and our [Accounts Legal] (doc:accounts-legal-disclosure) pages.
Updated almost 5 years ago