> For the complete documentation index, see [llms.txt](https://initiativ.gitbook.io/initiativ/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://initiativ.gitbook.io/initiativ/mm_internal/retained-from-version-0.1-not-yet-reworked/v01-12.8.3-custody-and-transfer-procedures.md).

# (v01) 12.8.3 Custody and Transfer Procedures

## 8.3.1 Exchange Account Structure

### Exchange Cash Account Structure

The Exchange maintains two types of accounts to manage Member cash while it is held on the Exchange:

**Custody Account:** All Member funds are deposited into a custody account by default, provided by \[Memo Bank / specify provider]. This account holds the pooled cash of all Members in segregated sub-accounts. The custody account is the primary operating account for all trading activity. Cash in the custody account does not generate yield for Members but is immediately available for trading and withdrawals.

**Yield Account (Optional Money Market Fund):** Members may opt to transfer a portion of their cash to a Money Market Fund (MMF) account provided by \[Spiko / DECIDE specify provider or not?]. This account holds cash that Members have allocated for yield generation. Cash allocated to the yield account generates variable returns that are credited to the Member, subject to the cut-off times and procedures described in Section 8.4.

**\[DECISION REQUIRED - Item 39]:** Confirm banking and MMF providers – confirm If we disclose them here or keep provider agnostic?

### Exchange Registry Account Structure

The Exchange maintains registry accounts for each supported emission allowance type:

**EUA Registry Account:** Linked to the EU Transaction Log (EUTL). Members’ EUA inventory is held in segregated sub-accounts within the Exchange’s master registry account.

**UKA Registry Account:** Linked to the UK Emissions Trading Registry. Members’ UKA inventory is held in segregated sub-accounts within the Exchange’s master registry account.

## 8.3.2 Cash and Registry Account Configuration

Members configure their external accounts via the Administration Panel.

### Bank Accounts

* Members designate primary, secondary, and tertiary bank accounts for deposits and withdrawals.
* Accounts are verified via test deposit (1-2 business days).
* Members designate which account is used for trading vs. billing.

**\[DECISION REQUIRED - Item 56]:** Enable credit/debit card payments for deposits and/or billing, or bank transfer only?

### Registry Accounts

* Members link their external EUA and UKA registry accounts.
* Members may request Exchange assistance if they do not have a registry account.
* Verification takes 2-3 business days.
* Option to join trusted registry list for faster transfers.

## 8.3.3 Cash Deposit Procedures

Members deposit cash into the Exchange via bank transfer to the designated custody account.

{% stepper %}
{% step %}

### Initiate bank transfer

Member initiates bank transfer from their verified external bank account.
{% endstep %}

{% step %}

### Notify the Exchange

Member notifies Exchange of incoming transfer (optional, expedites processing).
{% endstep %}

{% step %}

### Exchange receives funds

Exchange receives funds (typically 1-2 business days for SEPA).
{% endstep %}

{% step %}

### Credit Cash Balance

Exchange credits Member’s Cash Balance.
{% endstep %}

{% step %}

### Update Trading Limit

Trading Limit updated accordingly.
{% endstep %}

{% step %}

### Receive confirmation

Member receives confirmation notification.
{% endstep %}
{% endstepper %}

### Processing Time

* SEPA transfers: 1-2 business days
* Domestic EUR transfers: Same day or next day
* International transfers: 2-4 business days

**Minimum Deposit:** None

**Fees:** No deposit fees charged by Exchange

**TO BE COMPLETED:** Wire transfer instructions, reference codes, confirmation procedures

## 8.3.4 Cash Withdrawal Procedures

Members may withdraw cash from the Exchange at any time, subject to:

* Sufficient available Cash Balance (not reserved for open orders)
* Specified withdrawal destination account is verified
* No outstanding fees or obligations

{% stepper %}
{% step %}

### Request withdrawal

Member requests withdrawal via Administration Panel.
{% endstep %}

{% step %}

### Specify withdrawal details

Member specifies amount and destination bank account.
{% endstep %}

{% step %}

### Verify available balance

Exchange verifies sufficient available balance.
{% endstep %}

{% step %}

### Process transfer

Exchange processes transfer to Member’s bank account.
{% endstep %}

{% step %}

### Update Trading Limit

Trading Limit updated accordingly.
{% endstep %}

{% step %}

### Receive confirmation

Member receives confirmation notification.
{% endstep %}
{% endstepper %}

### Processing Time

* Withdrawals from **Custody Account**: 1-2 business days (SEPA)
* Withdrawals from **Yield Account**: 2-4 business days (due to MMF redemption time)

### Withdrawal from Yield Account

* If funds are in the Yield Account, they must first be transferred back to the Custody Account before withdrawal.
* Transfer requests submitted before 10:30 AM CET are processed same day (subject to MMF cut-off).
* Transfer requests submitted after 10:30 AM CET are processed next business day.

**Minimum Withdrawal:** None

**Fees:** No withdrawal fees charged by Exchange

**TO BE COMPLETED:** Withdrawal limits (daily/weekly), emergency procedures, dispute resolution

## 8.3.5 Inventory Deposit Procedures

Members transfer emission allowances to the Exchange via registry transfer.

{% stepper %}
{% step %}

### Initiate registry transfer

Member initiates registry transfer from their external registry account to Exchange’s master registry account, specifying Member’s sub-account identifier.
{% endstep %}

{% step %}

### Notify the Exchange

Member notifies Exchange of incoming transfer (optional, expedites processing).
{% endstep %}

{% step %}

### Registry processes transfer

Registry processes transfer (typically 2-3 business days).
{% endstep %}

{% step %}

### Credit Inventory

Exchange receives allowances and credits Member’s Inventory.
{% endstep %}

{% step %}

### Update Trading Limit

Trading Limit updated accordingly.
{% endstep %}

{% step %}

### Receive confirmation

Member receives confirmation notification.
{% endstep %}
{% endstepper %}

### Processing Time

* EUA (EUTL): 2-3 business days
* UKA (UK Registry): 2-3 business days

**Minimum Deposit:** None

**Fees:** No deposit fees charged by Exchange (registry may charge fees directly to Member)

**TO BE COMPLETED:** Registry transfer instructions, sub-account identifiers, confirmation procedures

## 8.3.6 Inventory Withdrawal Procedures

Members may withdraw emission allowances from the Exchange at any time, subject to:

* Sufficient available Inventory (not reserved for open sell orders)
* Specified destination registry account is verified
* No outstanding fees or obligations

{% stepper %}
{% step %}

### Request withdrawal

Member requests withdrawal via Administration Panel.
{% endstep %}

{% step %}

### Specify withdrawal details

Member specifies quantity, instrument, and destination registry account.
{% endstep %}

{% step %}

### Verify available inventory

Exchange verifies sufficient available inventory.
{% endstep %}

{% step %}

### Initiate registry transfer

Exchange initiates registry transfer to Member’s external registry account.
{% endstep %}

{% step %}

### Registry processes transfer

Registry processes transfer (typically 2-3 business days).
{% endstep %}

{% step %}

### Update Trading Limit

Trading Limit updated accordingly.
{% endstep %}

{% step %}

### Receive confirmation

Member receives confirmation notification once registry confirms transfer.
{% endstep %}
{% endstepper %}

### Processing Time

* EUA (EUTL): 2-3 business days
* UKA (UK Registry): 2-3 business days

**Minimum Withdrawal:** None

**Fees:** No withdrawal fees charged by Exchange (registry may charge fees directly to Member)

**TO BE COMPLETED:** Withdrawal limits, emergency procedures, dispute resolution