Field Notes
What examiners usually ask about customer fund safeguarding
Practical questions that surface during safeguarding discussions—and the records that help a fintech answer them calmly.
2 April 2026
Safeguarding conversations rarely begin with theory. An examiner typically asks which bank accounts hold customer money, who can move those funds, and how often the firm proves that customer balances are covered.
Keep a one-page account schedule that lists each safeguarding account, the legal title, and the signatory list. Pair it with the most recent reconciliation that shows customer liability versus available funds, including timing differences you already understand. If you rely on a trust arrangement, have the trust deed excerpt and the latest trustee confirmation in the same binder section.
Access matters as much as balances. Privileged users who can initiate transfers should appear in a recent access certification with a named reviewer. Gaps here are common: the reconciliation looks tidy, yet the people who can move money have not been reviewed since last year’s hiring surge.