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Guidance for Crowdfunders & Peer to Peer Platforms (Fintech)

The UK Crowd Funding Association has worked in collaboration with the BBA in the preparation of this summary of the requirements banks have for those of our membership seeking to open bank accounts.

This is a comprehensive checklist on what banks would expect to have as information from you and should be a useful tool for preparing yourself for discussions on account services with banks, as well as preparing paperwork to support any applications.

Clearly each bank will continue to make an independent assessment of individual applications and ultimately whether they can provide the services you are seeking, but this guidance should be helpful in facilitating that process.

So long as all the necessary information has been provided as listed below, the bank assessment and security check processes should usually take 10 working days. However if greater due diligence is needed, such as if you hold client money, or if documentation is missing, it could take longer.

This guidance contains information on the following:


For those of you holding client money:

The banking industry will generally apply guidance on such matters aligned to the Joint Money Laundering Steering Group. Where the crowdfunder holds client money in pooled accounts (whether in a bank account or through a securities holding), the crowdfunder will be obliged to verify the identities of their clients. Financial services firms with which such client accounts are held are not required to identify the beneficial owners of such funds, provided that the information on the identity of the beneficial owner is available, on request, to the firm. As a practical matter, firms may reasonably apply a similar approach to such client accounts which only contain the funds of a single beneficial owner.

It should be noted that Crowdfunding institutions do not currently meet the definition of a ‘credit institution’, and as such banks are unable to utilise the Money Laundering Regulations when assessing institutions. As such this drives the need for higher scrutiny, the requirement for detailed access to a variety of documents and the need for additional controls.

A full list of on-line application portals for UK business bank accounts can be found here

Details on officials and shareholders of crowd funders

  • Who owns the business (shareholders / ultimate beneficial owner)?
  • Details and biography of all key company officials and beneficial owners. Identity documents are likely to be required to be produced.
  • Evidence of source of funds and/or wealth in the business and of key officers/shareholders, if relevant.


A business plan which must include:

  • Overview of the model (inc sales process and route to market), including a description of services and product types.
  • Where the business has come from and how it has developed (inc management experience and track record) Current status of the business and future growth plans for the business.
  • Ideally 3 years financials showing Profit & Loss, Balance Sheet and Cashflow. But for new businesses projected financials will be requested.
  • Evidence that there is sufficient equity to cover operation until profitable, or alternatively plans are in place to source liquidity to ensure obligations are met.
  • Funds Flow Chart / Diagram (probably included in Business Plan) including how funds are collected/received (e.g. direct debit/electronic payments, cash etc.), how identified and how and when returned to clients.
  • Are any agents used to find clients i.e. borrowers?
  • Which channels does the business use – purely online?


Regulated Status

  • Regulated status?
  • Confirmation that all relevant registrations obtained i.e. FCA. If the business does not appear on the online register (e.g. FCA) written confirmation will be required from the regulator.
  • What investor protection is in place?
  • Web site details – to clearly state any risks for investors.
  • In which countries do you plan to operate – are there any you do not wish to operate in – why?
  • Details of the nominated MLRO & AML officials + contact details.
  • Clarification if deal with US based clients and confirmation of full jurisdictional reach of business and customers.
  • Client must evidence that the account will only be used for security deposits and maintenance fees and will not be used for rental income if property managers or estate agents.


Policies and procedures

  • Copy of AML Policy to evidence that they have AML procedures that comply with the Money Laundering regulations - and underlying KYC will be available upon request.
  • Your internal risk assessment on investors/ borrowers/ products (could be in Business Plan).
  • What the Sanctions Screening is for investors / borrowers / transactions.
  • How you would monitor for unusual transactions.
  • How you would monitor and report Suspicious Activity.
  • How you would deal with / record exited / declined requests / borrowers.
  • Does the customer have a robust training policy/plan that covers AML procedures? Is there an assessment and what is the pass mark?
  • What assurance/audit plan is in place?
  • Any testing of compliance by a third party
  • What platform contingency arrangements are in place? IT security against hacking, fraud, etc.
  • What is the records retention policy?


Services wanted

  • What banking services/products are you seeking to access?


Specific contacts in the following banks

Barclays Paul Bastow Paul.Bastow@barclays.com 07557 564 985
Clydesdale Judith Belmore Judith.M.Belmore@eu.nabgroup.com 07885 270 965
Cooperative Bank Ian Rigarlsford IanRigarlsford@cfs.coop 01612 013 987
HSBC Mike Conroy MikeConroy@hsbc.com 02079 910 621
Lloyds / Bank of Scotland Alex Mackie Alex.Mackie@LloydsBanking.com 07590 910 490
RBS/Natwest James Gardiner James.Gardiner@rbs.co.uk 07500 785 226
Santander John MacLeod John.MacLeod@santander.co.uk 07568 112 508

Additional contact points

Allied Irish Bank

  • At Allied Irish Bank, your local branch is your point for all customer contact. To find your local branch webpage, which lists staff contact details, see http://business.aibgb.co.uk/branch-locator
  • Contact point for enquires - www.aibgb.co.uk or 0845 600 5204 which is the Customer Service General Enquiry helpline
  • Contact point for complaints - www.aibgb.co.uk or 0845 600 5204 which is the Customer Service General Enquiry helpline

Bank of Ireland

Bank of Scotland

Barclays

Clydesdale Bank

Danske Bank

First Trust Bank

  • At First Trust Bank, your local branch is your point for all customer contact. To find your local branch webpage, which lists staff contact details, see https://personal.firsttrustbank.co.uk/branchlocator
  • Contact point for enquires - www.firsttrustbank.co.uk or 0845 600 5925 with member of staff at a Branch or Business Centre
  • Contact point for complaints - www.firsttrustbank.co.uk (contacts query form where complaint can be registered) or 0845 600 5925 with member of staff at a Branch or Business Centre

Handelsbanken

HSBC

Lloyds Bank

Natwest

RBS

  • On line Business account opening link - http://www.business.rbs.co.uk/afb/public/rbs/AFBRoot/mainhome
  • Contact point for enquires - 0800 121 129 or from abroad: +44 121 635 1595
  • Contact point for complaints - 08457 121 121 or from abroad: +44 8457 121 121 Online:- RBS Non-Customer Complaints https://www.rbs.co.uk/global/h/contact-us/personal-banking/complaint-form-js.ashx

Santander

The Co-operative Bank

Ulster Bank

Yorkshire Bank