In early 2019, agents were approaching agentOS to ask what we were going to do about accounting for 100s of separate landlord accounts within the system, which was the first time we realised that client accounts were being withdrawn due to the 2018 5th AML Directive.
Agents were being forced to give up precious income to pay a £8 to £22/m fee per landlord account, or having to outsource to a client account service provider in order to just get a client account. This was endangering their livelihoods with such vastly increased costs and the risk of losing a client account.
Calmony is the blending of online banking, online payment services and same day BACS payments all in one online client account.
Agents no longer need all three separate services with high percentage charges when taking payments and outdated BACS charges for uploading bulk payments just for the privilege of paying their customers on the same day.
With banking of client money comes great responsibility for Calmony and our agents. The general consensus of The Letting Partnership is that CMP schemes health checks finds that misuse of client funds is not usually the owner of the agency but the people they employ and trust.
By going beyond what high street banks do to protect your money, Calmony requires payees to be AML checked and monitors account usage to safeguard all of us from misuse of client money and AML crime.
Calmony’s next steps are to explore the financial regulation and services needed to help agents achieve interest on money held in Calmony deposit and trading accounts.
Followed by introducing landlord accounts that will automatically submit their quarterly tax returns with ‘making tax digital’ which is required from April 2024.
We started this journey with a technical question on how we would account for 100s of separate landlord client accounts. The outcome is now protecting agents’ livelihoods by becoming a Neobank that ensures they can get and afford to keep their client account.
An Electronic Money Institution (EMI) is a provider of e-money. This money is stored electronically in digital wallets.
Calmony is not a bank but an e-money institution authorised under the UK Electronic Money Regulations and is FCA registered 850923. All EMIs must follow safeguarding laws to protect your client money. These laws are designed to ensure that if the e-money institution fails, your money will have been kept in a safe place.
Click here for more information about EMR regulations
Calmony is an FCA registered (850923) Electronic Money Directive (EMD) and Payment Services Directive (PSD) agent.
Calmony is committed to protecting our consumers and their customers credit and debit card data in compliance with the Payment Card Industry Data Security Standard (PCI DSS).
We conduct regular vulnerability scans and penetration tests in accordance with the PCI DSS requirements for our business model.
Bank of England
The Calmony client account is an electronic money account with payment services provided by Modulr Finance Ltd who are an authorised Electronic Money Institution with the money held in a Bank of England bank account.
Modulr FS Ltd (FRN: 900573) is licensed as an authorised E-Money Institution (EMI) and regulated by the Financial Conduct Authority (FCA). Calmony is a trading name of agentOS Proptech Group Ltd and is registered as a PSD agent with the Financial Services Authority, reference number 850923.
This enables Modulr to issue electronic money (e-money) to its customers, hold customer funds in safeguarded e-money accounts, and provide related payment services to customers.
Payment services in the UK are subject to the Payment Services Regulations (PSRs).
The PSRs apply to all payment services, meaning that in relation to payment services, there is no difference in how Modulr or other payment service providers and banks are regulated.
In line with Modulr’s regulatory requirements, 100% of customer funds related to the e-money that Modulr FS Ltd has issued are segregated from Modulr’s own funds, and safeguarded in a Bank of England account. As such, e-money in Modulr accounts is protected from any risk connected with Modulr’s or solvency.
In line with the Electronic Money Regulations, Modulr FS holds additional “own funds” to the value of 2% of the safeguarded balance. EMIs like Modulr Fs Ltd have a responsibility to notify the FCA should the “own funds” fall below the 2% mark.
The “own funds” requirement and safeguarding requirement means customer funds are 100% available to a customer, and there is a protection mechanism to help ensure an orderly wind down of an EMI if required.
While the Financial Services Compensation Scheme (FSCS) is not applicable in relation to e-money products, the regulatory regime outlined above can be relied upon and protects the full balance of customer funds, as opposed to protecting up to a cap (as under the FSCS).
Meaning, we use safeguarding to protect 100% of your money while the FSCS is limited up to a total of £85,000 for individual accounts.
With regards to money laundering and the Proceeds of Crime Act, Modulr has the same obligations as other payment service providers and banks.