Digital Wallet & Custodial Account Creation

Creating an Electronic Wallet or custodial sub-account is subject to identity, provisioning, data-handling, and record requirements. The normal path, failure path, and recovery handoff are in Wallet and transfers.

Applicability and identity gate

In a regulated investment platform, an Electronic Wallet is a distinct custodial account or sub-account tied to a verified person or entity. Before funds can be accepted, stored, or deployed, the applicable compliance process establishes a reasonable belief in the customer's identity under the USA PATRIOT Act and Customer Identification Program (CIP) rules.

The wallet creation constraint is:

• The Investor completes KYC with the KYC provider before the wallet service creates or enables the wallet record.
• The Investor supplies full name, government-issued ID, and Taxpayer Identification Number (SSN/EIN).
• The KYC provider must return VERIFIED before the wallet service creates the wallet.
• Anonymous or sanctioned accounts cannot be created.
• Entity profiles, including LLC or trust profiles, can require manual Beneficial Ownership review.

The KYC provider returns the identity result. The wallet provider receives the verified handoff and creates the Wallet ID. The applicable compliance owner still determines the required profile and jurisdiction checks.

VERIFIED is the provider-specific KYC event label; it is distinct from the platform's Profile.kyc_status=approved field and the wallet lifecycle's lowercase verified state.

Provisioning and data handoff

After the KYC provider returns VERIFIED, the wallet provider receives the verified data through its Customer Verification System (CVS) or equivalent provider interface. The provider's risk decision and the wallet service's provisioning result determine whether a Wallet ID is created and linked to the Investor's profile.

The provisioning handoff is covered by Onboarding an Investor and Wallet and transfers.

Data security and handling standards

Sensitive PII remains subject to the applicable identity and security controls. NIST Special Publication 800-63B provides the digital identity reference. Sensitive identity documents pass directly to the secure KYC provider and are not stored in the platform's primary database. All data in transit uses TLS 1.2 or later.

Records and evidence

The wallet record and its WORM audit trail identify:

• The identity verification result and provider reference.
• The Wallet ID, profile link, creation timestamp, and provisioning decision.
• The provider response, manual-review decision, or failure reason.
• The identity verification timestamp and notification records needed for later review.

The identity verification and wallet creation timestamps are stored in WORM (Write Once, Read Many) records. All account communications, including the Wallet Created communication, are archived and accessible for at least five years.

Retention references for identity, account, and communication records include SEC Rule 17a-4(f) and FINRA Rule 4511. The responsible compliance owner determines the applicable retention period and storage controls.

See Reference for the Wallet and state lifecycle records. Use Wallet and transfers for the unique normal, failure, and recovery sequence.