Corporate Source of Funds (SOF) Overview
Background
Previously the monthly SoF declarations were triggered for a corporate depositing a cumulative 15K or more in a month period. A new cumulative 50k threshold will now apply across a rolling seven-day period. This is a substantial increase in the threshold, supporting a higher volume of deposits. Funds will also only be flagged for review if there is a sudden change in deposit behaviour for the Corporate.
Significantly, as part of our new model, if the source of the funds is known; through previous transaction activity and SoF information, and is part of the expected behaviour for the Corporate, the transaction will not be flagged but will be processed automatically, without SoF being required.
Criteria for Flagging Unusual Transaction Patterns
The following criteria are used to flag unusual transactions - everything else is expected to be processed without delay:
If a single deposit, or cumulative deposits, received equates to 50K, or above, within any rolling seven-day period, and the source is different from previously understood transaction sources or SoF information, or documentation has not previously been provided in connection with the source account, we will flag the transaction and initiate an SoF process in order to obtain the necessary information. The first time a Corporate reaches this threshold without the necessary information being known this will be established; via the SoF process.
The existing upper monthly cumulative threshold will remain in place, currently defined as 100K (unless otherwise agreed) over a rolling 30 day period. If a single deposit, or cumulative deposits, received reaches or exceeds, this threshold the transaction will be flagged and a SoF process will be initiated.
SoF Review Process
In the event of a SoF Review being flagged, the completion and return of the SoF documentation (including supporting documentation), will have an expectation to be completed within 3 business days from the date of the SoF Review being initiated.
If the SoF is not returned within the allotted time frame further steps may be taken in connection with the Corporate, such as the suspension of the associating deposits managed account suspension. We will of course take every effort to avoid this, and use a pragmatic approach. To help avoid any complications it is recommended that more than one person within each Corporate is set up to be able to complete such documentation.
The normal process steps for progressing a SoF are as follows:
Transaction occurs and SoF requirement identified
Weavr team generate the necessary SoF (via Pandadoc). A notification is triggered to the corporate root user email address (held on file) advising of the SoF document and need to complete.
In parallel the Weavr team generates a support ticket to the related embedder contacts advising of the SoF creation and pertaining corporate.
The corporate completes the SoF form and digitally signs this (via Pandadoc).
In parallel the corporate provides supporting documentation to the embedder in order to upload to the support ticket. [Separate guidance on correct completion of the SOF form and supporting documentation can be provided].
Once both the SoF form and supporting documentation are received the Weavr team will conduct a review of the information.
If all necessary information is supplied and passes review the funds will be authorised and credited to the account.
If there are any issues with the documentation or SoF form the Weavr team will provide feedback and instructions on this via the support ticket with the embedder (funds will not be credited at this time).
What to Expect
The following are some example scenarios:
A Corporate with an upper monthly deposit limit of 100k, and has a normal behaviour of depositing 25k regularly each week from the same known source, a SoF process would not be initiated.
A Corporate with an upper monthly deposit limit of 100k, and has a normal behaviour of depositing 25k regularly each week, but has an irregular deposit within a given month, but the deposit is from the same known source and cumulatively the deposit amounts remain below the upper deposit threshold (100k), a SoF process will not be triggered.
A Corporate with an upper monthly deposit limit of 100k, but normal deposit behaviour is not known, or their previous behaviour is irregular deposit amounts from separate sources, a SoF process will be triggered on the first singular or cumulative deposit at or above 50k, received within a seven day period. (If further deposits are received within subsequent weeks which also exceed 50k, and the source is not the same a SoF process will be triggered)
A Corporate received a SoF request within a week for funds reaching or exceeding 50k. A further deposit is received for the same Corporate within the same week, which also exceeds 50k and is from a different source, a further SoF process will be triggered for the further deposit.
A Corporate received a SoF request within a week for funds reaching or exceeding 50k. A further deposit is received for the same Corporate within the same week, from the same source, but exceeding the Corporates upper monthly deposit limit, an additional SoF process will be triggered for the funds exceeding the limit.
The more information that is understood on each Corporate, and the more deposit behaviour that remains consistent; inside threshold expectations, from the same source, the fewer SoF processes will be necessary.
We understand that the translation behaviour of Corporates can adapt over time. This is something we can adapt with; as long as there is continued collaboration. This also provides the opportunity to adjust the upper monthly limit thresholds when applicable.
It is important to note that SoF can also be triggered for any deposit transaction; if this is identified as being pertinent. However, such cases are expected to be rare and we will be doing everything possible to collaborate with you to avoid any such out of the ordinary cases.