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 (), and maintain the functionality of deposit (SUBACCOUNT-US) or savings accounts (IB-SUBACCOUNT-US) while having fewer KYC requirements.

Because FBO Accounts keep the platform in the flow of funds, MSB - MSB - A money services business (MSB) is a legal term used by financial regulators to describe businesses that transmit or convert money. Businesses that transmit money or representatives of money, provide foreign currency exchange, cash checks, or are in the some other way in the flow of funds are usually considered MSBs Please, consult with your attorney if your services fall under this definition. Synapse and its partner banks may require a legal opinion letter from your counsels to attest that your Platform does not need MSB registration or Money Transmitter States Licenses to operate. For more information, please refer to https://www.fincen.gov/money-services-business-definition Last updated July 2019 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 - MSB - A money services business (MSB) is a legal term used by financial regulators to describe businesses that transmit or convert money. Businesses that transmit money or representatives of money, provide foreign currency exchange, cash checks, or are in the some other way in the flow of funds are usually considered MSBs Please, consult with your attorney if your services fall under this definition. Synapse and its partner banks may require a legal opinion letter from your counsels to attest that your Platform does not need MSB registration or Money Transmitter States Licenses to operate. For more information, please refer to https://www.fincen.gov/money-services-business-definition Last updated July 2019 or MTL registration (or an exemption) and wishes to collect less KYC.

Previous Steps

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

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 Businesses

Base Documentation

Business Name, Address, Entity Formation Date, Entity Type (e.g. LLC, Corp, etc.), Entity Scope (Industry), Business Email (if unverified: 2FA), Phone Number (if unverified: 2FA).

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.

FBO Accounts


SUBACCOUNT-US IB-SUBACCOUNT-US

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