Question 1

How does Freemarket safeguard my money?

Accepted Answer

Freemarket holds clients’ money in safeguarding accounts with its banking partners. These funds are held separately from Freemarket’s own operational funds and working capital. Freemarket’s banking partners are required to warranty that the safeguarded funds will not be used to satisfy or offset any other obligation including those obligations imposed on Freemarket itself. This means that the funds can only be used to make payment for the underlying Payment Services User. If that instruction is unable to be complied with, Freemarket must return the funds to the original source.

Freemarket does not maintain a safeguarding account for each individual client. Rather, Freemarket holds pooled accounts in the name of “FreemarketFX Ltd Client Accounts” in each currency for the purpose of providing payment services.

Individual clients’ funds in safeguarding accounts are identified through your Freemarket virtual payment account number and/or virtual reference number. These records are used to reconcile credit, debit and balance transactions each day such that (i) the recorded positions individually show what amount of the total balances held is attributable to you; and (ii) the individual amounts recorded in virtual accounts add-up to the total balance held in the real account. Freemarket also moves fees and charges out of the safeguarding account to its own account as it is required to do so at least daily.

Freemarket’s banking partners are credit institutions authorised in the UK and in the European Economic Area.

Question 2

How safe is my money?

Accepted Answer

As a condition of its authorisation as an API by the FCA, Freemarket is required to protect and keep safe its customers’ funds. Specifically, Freemarket must comply with the Payment Services Regulations 2017 (PSRs). These regulations stipulate that APIs must have appropriate and well-managed safeguarding arrangements to ensure client funds are not subject to any other claim and that in the event of insolvency, are returned to the client in full, and in a timely and orderly way.

This is set out in detail within:

PSRs regulation 23; and
Chapter 10 of the FCA Approach Document

Freemarket is not a bank; your account with Freemarket is a payment account rather than a bank account. The funds provided to Freemarket for the purposes of making a payment are not eligible for depositor protection via the Financial Services Compensation Scheme (FSCS).

Question 3

Which types of transaction must be safeguarded?

Accepted Answer

In PSRs, safeguarding applies to what are described as ‘Relevant Funds’. These are defined as sums received:

from, or for the benefit of, the Payment Services User for the execution of a payment transaction, and
from another Payment Services Provider (either a bank or non-bank) for the execution of a payment transaction on behalf of a Payment Services User

Consequently, Freemarket is obliged to safeguard any monies you transact through us including bank transfers, withdrawals and foreign exchange. Freemarket’s own funds must be held in different bank accounts.

Question 4

Can I have confidence in your safeguarding processes?

Accepted Answer

Freemarket undertakes an annual audit of its compliance with the PSRs 2017 safeguarding requirements. This can be done through a self-certification process, or via an independent audit.

The audit must show that Freemarket (i) has an up-to-date safeguarding systems and controls manual, (ii) holds records which demonstrate and explain the rationale behind its safeguarding decisions, and (iii) fully discharges its safeguarding obligations as prescribed by the PSRs.

How does Freemarket safeguard my money?

How safe is my money?

Which types of transaction must be safeguarded?

Can I have confidence in your safeguarding processes?

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