How to submit a detailed Flow-of-Funds (FoF)?

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In order to start processing forward, here is what I would like you to do. As you have a deeper understanding of your product (and ‘assume’ we do not), explain your transaction(s) set and flow of funds to us. A transaction set is a financial movement task (payment, processing, etc.) that can be performed on the system you are envisioning. For us (and in turn the solution provider to better understand how this all works, you need to explain it to us, no matter how right or wrong it is. Legally, the transaction set and the flow of funds have to come from you, only then to be edited by us &/or the solution provider to make it fit into the regulatory mold of the solution provider in question. 

DO NOT RUB ANYTHING FROM THE WHITE-BOARD.

  1. Take a white sheet of printer paper (use multiple papers if required) or use a white-board.
  2. Draw our rough circles (or boxes) depicting the various geographies you might be working with. Like 3 circles, one would be the US, and one could be EU and one could be Singapore. etc. You get a general idea.
  3. Next show the entities, for example, draw a stick man to depict a user in the EU or US. Draw a small house to depict a business, etc., and use arrows to explain from WHERE the transaction is originating, and TO WHOM the transaction is going to benefit (i.e. be terminated/credited to). 
  4. Use some figures to show. For example, A customer (depicted as a stick man on the paper/board) in the US decides to send US$ 100 to a business (depicted as a house on the paper/board) in Singapore. And the business receives S$ XXX.00 and shows what happened, how the transaction was transported (or settled across) if you want to provide us with such details.
  5. Any conversions, or any magic that you wish to perform, etc. should clearly be identified. 
  6. At all times, try to show the flow of money, the flow of funds.
  7. Try to be as granular as you can be.
  8. Also, if you can, as many places as you can, tell us who (as in which entity) has possession of the funds. This is extremely critical. 
  9. ANY TIME!!!! We mean at any time if YOU have control of customer funds, even for a second, mention that. This is also extremely critical.
  10. Do this for all of your transactions.

Now comes the best (easy) part. 

Take your mobile phone out and start video recording. Now record the video while explaining what is happening on the paper (or on the whiteboard).

It’s okay if your hair is in a mess or if you have not shaved. We don’t care. All we care about is the video and you, explaining in your own voice, what is happening. 

Once this is done. You can send the video via WhatsApp: +13129576797 (be sure to mention on the WhatsApp message who you are). Alternatively, you can email the WeTransfer service. We will not accept files in any other manner. Okay, maybe as a Google drive link.  

If you wish to learn more about Flow of Funds, you can visit this link: https://nomisma.digital/solutions/licensing/money-transmitter-license-mtl/understanding-the-united-states-money-transmitter-licensing/what-is-a-flow-of-funds-or-fof-for-short/

Looking forward to your submission.

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This page was last updated on August 31, 2021.