Funding Source Verification & Bank Account Linking
In a regulated investment environment, linking a bank account is not simply a convenience feature; it is a compliance process known as Source of Funds Verification.
To comply with the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) statutes, the platform must ensure that the capital entering the ecosystem originates from a legitimate financial institution and that the investor controls the account in question. This creates a trusted "ramp" for moving funds into the Electronic Wallet.
1. The Linking Mechanisms (Nacha Compliance)
The platform provides two distinct methods for linking an account, both designed to satisfy Nacha Operating Rules regarding "Account Validation" for WEB Debits.
Method A: Instant Verification (Credential-Based)
Process: The user authenticates directly with their bank portal via a secure API provider (e.g., Plaid, MX).
Compliance: This satisfies Nacha requirements immediately by proving ownership and checking the account status (open/active) in real-time.
Method B: Manual Verification (Micro-Deposits)
Process: The user manually enters routing and account numbers. The system sends two small deposits (e.g., $0.03) to the account. The user must return to the platform and confirm these exact amounts.
Compliance: This traditional method proves that the user has authorized access to the account statement, satisfying the requirement for authorization.
2. Data Security & Tokenization
Handling bank account credentials requires strict adherence to data privacy standards to prevent unauthorized debits.
Tokenized Architecture
In compliance with NIST 800-63B standards, the platform utilizes a "Tokenized" storage model.
No Raw Data: The platform never stores the user's raw bank account number or routing number in its primary database.
The Token: Instead, the banking provider returns a secure, encrypted "Processor Token." The platform stores only this token. When a transfer is initiated, the platform sends the token to the processor, ensuring that sensitive banking details remain isolated from the application layer.
3. Record Keeping & Change Management
Adding or removing a funding source is considered a "Material Change" to the user's financial profile.
Audit Trails (SEC Rule 17a-4)
Retention: The specific timestamp, IP address, and verification method used to link the account must be legally archived.
Fraud Prevention: Under FINRA Rule 4511, the system must generate an immediate notification for any change in funding sources. This alerts the user instantly if a malicious actor attempts to link a fraudulent account to their wallet.