Who gets the interest on funds held?
No interest can be paid or credited to any customer as we would then be offering savings facilities to our customers. The FCA considers that we would not then be holding funds “only in relation to payment transactions” and would be in breach of regulation 33 of The Payment Service Regulations 2017.
Because we hold clients’ money in our client account purely as a stakeholder, funds are not held for investment and are not, therefore, Custodial Accounts as defined in sub-paragraph 1(u) of Article 1 of the FATCA Agreement 2012.
Any interest earned in the account is retained by Security for Expenses Ltd. A proportion is held as capital reserve in anticipation of likely changes in regulatory requirements. Some is used to meet running costs and keep fees down and some is given to charity, principally UNICEF and Feedback Madagascar.