COMPLIANCE005 - XTRM Financial assurance

XTRM Financial Assurance

XTRM  is a financial technology company. To guarantee financial good practices and ensure customers have the required confidence and financial assurance to do business with us, we are regulated in all regions as a Money Service and Money Transmitter business. As such, all of your funds are protected in two ways:

1.      Federal regulation

2.      By State regulation

Under State regulation, we must hold significant funds in a surety bond to protect client funds.

Regulatory Oversight

XTRM receives regulated oversight by both participating banks and Corpay, Inc. (Corpay) as a licensed and regulated money transmitter, or its equivalent, by all regulatory agencies, both state and federal. 

As a license requirement, we are required to own eligible securities having an aggregate market value computed by the United States generally accepted accounting principles of not less than the aggregate amount of all of its outstanding payment instruments obligations issued or sold by the Company and all outstanding money received for transmission by the Company. In addition, eligible securities, even if commingled with other assets of the Company, are deemed to be held in trust for the benefit of the purchasers and holders of the Company’s outstanding payment instruments and stored value obligations, and all senders of outstanding money received for transmission, in the event of bankruptcy or receivership of the Company, or in the event of an action by a creditor against XTRM who is not a beneficiary of this statutory trust. This requirement is scrutinized with regularity through examinations, audits, and periodic reporting obligations. 

As such, we maintain at all times permissible investments that have an aggregate market value computed following generally accepted accounting principles of not less than the aggregate amount of all its outstanding payment instruments and other transfers. 

Furthermore, as a license requirement or licensing application process, we currently maintain surety bonds in all jurisdictions that were licensed for the benefit of its clients. The proceeds from these bonds are to be used only in the event of insolvency or bankruptcy by XTRM.

Corpay General Overview

Corpay provides MSB licensing and surety bonding for XTRM and XTRM partners and customers.  Corpay was founded in 1979 and has become one of today’s largest privately owned global currency exchange and risk management solutions providers. They have over  35,000 businesses and individuals worldwide, processing currency exchange and money movement of over 180 countries around the clock every day. Corpay fully adheres to international payments and regulatory requirements. Regulatory obligations require Corpay to safeguard all client funds and segregate certain funds, providing clients with the confidence they transact securely. In addition, sophisticated data encryption is used to ensure privacy and data security.

FinCen MSB Registration Number: 31000180270800 & 31000203165707 (NV)

Registration Type: Corrected Report, Re-registration

Legal Name: Cambridge Mercantile Corp. 

DBA Name: Corpay

Corpay Security Of Funds Overview

Corpay, Inc. and its subsidiary and affiliated entities (collectively “Corpay”) are regulated in over fifty global jurisdictions. Consequently, the legislation and regulation governing its payment activity vary from jurisdiction to jurisdiction. However, one of the commonalities among all jurisdictions is the legislative intent to ensure the pecuniary safety of customers. This is accomplished through two general tranches of legislative protections.

The first tranche involves protection afforded to mitigate the occurrence of an insolvency event. Many jurisdictions stipulate that Corpay maintains certain capital requirements. These provisions help to ensure that Corpay operates under sound financial health. Another legislative tool to help mitigate the occurrence of an insolvency event is the requirement to safeguard funds. Numerous jurisdictions require Corpay to maintain certain eligible assets to cover the funds it receives from its customers for payment activity. The aforesaid requirements are scrutinized with regularity through examinations, audits, and periodic reporting obligations.

The second tranche involves the protection afforded in the occurrence of an insolvency event. In the event of insolvency, many of Corpay's regulatory authorities have certain legislative tools to help ensure the customer is made financially whole. For example, many jurisdictions stipulate that customers receive a senior debt preference. As a result, obligations owed to customers are paid before obligations owed to non-customer creditors (i.e., junior debt holders). Additionally,  Corpay is required to maintain surety bond coverage in certain jurisdictions within the United States. These United States customers are entitled to a claim on the surety bond for damages incurred by Corpay's failure to perform a contractual obligation. Finally, many regulatory authorities have the ability to place Corpay in receivership. In this event, a receiver is appointed to run the company and manage the distribution of assets. The receiver would adhere to the above-stated debt preference hierarchy.