Speeding Up AML:
One of the most time consuming and manual processes we deal with is AML on investors and issuers. Until recently, when using any sort of company or custodial entity, manual follow-up was almost always required by the FundAmerica staff. This is because AML requires us to “travel up the chain” so to speak in order to get to a real person.
As many investors invest as companies and trusts and all issuers must be corporate entities, we’re forced to manually collect additional information on the owners and associated persons.
While this manually-intensive process is never going to be entirely eliminated (AML via API is imperfect), if you want to reduce hassle on your issuers and investors as much as possible, please make use of our recently introduced Entity Relationships feature. This allows you to connect people with companies. When investments are placed or escrow service applications are submitted on an entity with a parent or parents, AML checks will be processed on all of them.
It is very likely that this becomes a requirement in the coming months as opposed to a suggestion, so the sooner you get to coding, the better!
NEW: Optional Subscription Agreements
This announcement will probably met with a combination of groans (developers who have already coded for this) and cheers (developers currently coding). In most cases, submitting subscription agreements with investments is now optional. Keep in mind, there is a glaring exception:State Securities and KYC. If you plan on using this service, we do need subscription agreements with the investment.
With that said, the flow is also far more flexible. An investment can have the accompanying subscription agreement added at any time before closing. For those of you doing a lot of debt offerings, this is likely to be a big help in structuring your flow. The biggest procedural change caused by these changes is that when using the KYC service you cannot complete a close request until all investments with received funds have valid subscription agreements attached to them.
Other New API Features:
The bank wire information for offerings and investments has been expanded. While many large banks don’t seem to mind an account number and routing number, many smaller banks want a lot more information. We now include the bank phone number and the beneficiary information in related API calls.
We’re in the process of adding a lot of new features directly to the browser-accessible control panel. In the coming weeks you will be able to submit investments, escrow service applications, define entity relationships and, in theory, run an entire offering without needing the API if you have deals you’ve just got to get going and don’t have time to wait for your engineers. The browser-based control panel has played second fiddle to the API in terms of development over the last few months but we’ve learned from our platform customers that while their engineers are fine working through the API, the executives do not always have the time to wait for it to be done before getting their deals online.
If you have any questions or concerns, feel free to contact me directly!
Joshua Hansen, Chief Engineer