How Makeba Markets holds, safeguards and accounts for Client money, in accordance with the FAIS Act, the General Code of Conduct, and sound treasury practice.
This Client Funds and Segregation Policy sets out how Makeba Markets (Pty) Ltd (FSP 53160) holds, safeguards, and accounts for Client money, in accordance with the FAIS Act, the General Code of Conduct, and sound treasury practice.
As a Category I Financial Services Provider, the Company is required to keep Client funds separately identifiable from its own funds at all times, to use Client funds only for purposes authorised by the Client or permitted by law, and to maintain accurate, up-to-date records of each Client's entitlement to funds held.
Client funds are held in bank or electronic money institution accounts separate from the Company's own operational accounts, such that Client funds do not form part of the Company's assets and are not available to the Company's general creditors in the event of the Company's insolvency. The Company reconciles Client fund balances against internal ledgers on a regular basis to ensure that the funds held match the Company's record of amounts owed to Clients.
During the Company's interim operational phase, and prior to the finalisation of its consolidated corporate operating account infrastructure, Client deposits may be collected via individually named and identifiable virtual IBANs (vibans) issued in each Client's name through the Company's electronic money institution or banking partner(s).
This structure allows each Client's deposits to be individually identified and reconciled at source, rather than commingled in a single pooled company-name account, providing an additional layer of transparency and traceability during the interim period. Funds received via named vibans are allocated to the relevant Client's trading Account promptly upon confirmation of receipt and completion of any applicable verification checks.
The Company will transition to its long-term client money architecture as its banking and payment infrastructure is finalised, and will notify Clients of any material change to how their funds are held.
Client funds are not used to finance the Company's own operations, are not lent to third parties, and are not used as security for the Company's own obligations, save as may be permitted by Applicable Regulations or with the Client's specific written consent.
Unless otherwise agreed in writing or required by law, the Company does not pay interest on Client funds held on Account.
The Company performs periodic internal reconciliations of Client money records against actual balances held with its banking and payment partners, and maintains records of all Client fund movements for the period required under Applicable Regulations.
In the event of the Company's insolvency, segregated Client funds are, in principle, intended to be returned to Clients ahead of distribution to the Company's general creditors, subject to the applicable insolvency law process. Clients should note that South Africa does not operate a statutory investor compensation scheme, and segregation reduces but does not eliminate the risk of loss.
This Policy is reviewed at least annually and upon any material change to the Company's banking, payment, or client money arrangements.