The custody check
Everything on this desk reduces to one habit: find out what the operator is required to do with the money it holds, and write down what you found while everything is working normally.
- Read the terms, and read for mechanism words. Find the section on how customer funds are held. Look for an account, a trust, a reconciliation, a frequency, a duty, a policy, a cap. If the section contains only adjectives - secure, safe, protected, safeguarded - then no mechanism has been disclosed and the lookup has produced its answer.
- Find the licence condition. Go to the register of whichever authority licences the operator, find the operator's entry, and look for conditions rather than permissions. Where the register does not publish conditions, that is a finding too: the constraint on the operator is not publicly stated.
- Look for a published customer-money statement. Some regimes require the operator to publish how customer money is held, and some require it audited. If one exists, it is the best document available, because it reports on money rather than on rules.
- Identify the shape of the rule. Separation only, separation with a duty, a graded tier, or cover by policy or guarantee. The shape tells you which gap applies - and therefore what the arrangement does not answer.
- Record what you found, with a date, and keep it. A dated note and a current statement are the only evidence a player can hold, and both are trivially easy to make now and effectively impossible to reconstruct later.
| What you find | What it proves | What it does not prove |
|---|---|---|
| A named account, a frequency and a top-up duty | That a mechanism exists and that a shortfall must be corrected | That the duty was performed between the last check and now |
| Separation named, no duty mentioned | That the money should be kept apart from the operator's own | Anything about quantity, and therefore anything about a shortfall |
| Cover named, with an amount | That a policy exists and its cap | That the event which occurs is the event the policy covers |
| A tier or grade | What the regime requires at that tier | That the operator is compliant, or that the tier means the same thing in another regime |
| Adjectives only | That the operator has not disclosed a mechanism | Nothing further - the check is complete, and the answer is the absence |
Five sentences worth recognising
These are the shapes a terms section usually takes. Only the second and third describe a mechanism that can be audited.
"Customer funds are held in accounts designated for that purpose, separate from the company's own funds, reconciled daily, and any deficit is restored within one business day." Named account, purpose restriction, frequency and duty - four mechanisms in one sentence.
"The safety of customer funds is of the utmost importance to us and funds are held securely." No account, no purpose, no frequency, no duty, and nothing about shortfall. The sentence cannot be true or false, only reassuring.
customer-money statement a search, shape of the rule one reading, dated note one sentence
what the check produces: either a mechanism, a tier, or an absence
and the absence is the most useful result, because it ends the question instead of deferring it
a check done in five minutes now is worth more than a search done five days after a failure
This page explains how to read published documents. It does not tell a reader which operator to use, does not rank operators, and does not advise on moving or withdrawing money. Where a document does not exist, the honest conclusion is that it does not exist.
The partner link below is a disclosed sponsored link and the only commercial element on this page. This desk has no view on which operator holds money well, and no check on this page produces a recommendation.
Open the partner accountWhere to go next
- The condition in the licence - the four shapes, in detail.
- Seven beliefs, checked - the ones that survive a five-minute check and the ones that do not.
- Questions - the queries that bring readers here most often.
A mechanism A tier or a cap An absence