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REGULATED CLIENT ACCOUNT

The dedicated liquidity account

Asset management companies (AMCs) are required to segregate the cash of the funds they manage from their own funds in a regulated client account. Memo Bank is one of the only credit institutions licensed by the ECB to offer this type of account, managed via API in real time, with automated reporting to the custodian bank.


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What is a dedicated liquidity account?

The dedicated liquidity account is a regulated bank account, held in Memo Bank's books, designed to hold and safeguard the cash of an investment fund — such as an AIF (Alternative Investment Fund, including SCPIs, FPCIs, FIPs, OPCIs, securitisation vehicles, and private equity funds) or a UCITS (SICAV, FCP).


The account holder depends on the legal nature of the fund:


  • For an AIF (without legal personality): the account is opened in the name of the AMC, acting as representative of the fund. The amounts deposited are recorded off-balance sheet and do not belong to the AMC.
  • For a SICAV (with legal personality): the account is opened directly in the name of the SICAV.

In both cases, funds are strictly segregated: they cannot be seized by the AMC's creditors and are protected in the event of AMC failure.



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Spiko opens dedicated liquidity accounts for its SICAVs

Spiko, a specialist in corporate treasury investment, opens a dedicated liquidity account per sub-fund of its SICAV in Memo Bank's books. Daily investor subscriptions and redemptions are fully automated via API in real time. Memo Bank transmits a daily MT940 report to the depositary CACEIS, enabling it to fulfil its oversight obligations without any manual intervention from Spiko.


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Relation with the depositary

Memo Bank acts exclusively as account bank (cash account keeper). The depositary role (overseeing compliance of fund management with the fund prospectus) remains with the depositary chosen by the AMC.


Depending on the complexity of the arrangement (with or without a delegate, a depositary), a specific agreement must be signed with the relevant parties. Memo Bank holds tried-and-tested contract templates approved by regulators, which significantly accelerates the set-up process.

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The dedicated liquidity account

The dedicated liquidity account has its own IBAN and is fully manageable via API.


It earns interest, by default, at 25% of the €STR, calculated daily and paid out monthly.


Développeur recevant un webhook de virement entrant via l'API Memo Bank
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Access rights management for stakeholders

Access rights are configured within the account agreement. The AMC holds full administration rights on the account. It can delegate operational rights to a third party (collections and disbursements via API, with their own keys) whilst retaining overall control. The depositary is granted read-only access or receives a daily Swift MT940 report for its regulatory oversight obligations.


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A dedicated liquidity account managed via API

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Why orchestrate flows via API

Managing flows with our premium API in real time enables full automation of all operations. Collections (subscriptions, SEPA direct debits) and disbursements (dividends, redemptions, asset acquisitions) are fully automated from the AMC's systems, with a real-time webhook notification at each event.

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Payment routing via virtual IBANs

You can generate virtual IBANs via API for each investor at the point of onboarding. Each incoming transfer is automatically identified and reconciled. The same virtual IBAN is used to redistribute dividends and repayments back to the investor (pay-out).

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Dedicated liquidity account features

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About the dedicated liquidity account

Account holder: AMC (for AIFs without legal personality or UCITS) or the SICAV / fund with corporate form directly
Account name: can be customised
Negative balance: not permitted
Bidirectional virtual IBANs: available on request
Reporting: Swift MT940
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Remunerated deposits

25% of the €STR by default
Monthly interest payments credited to the dedicated liquidity account itself
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Incoming and outgoing flows

Incoming direct debit (SDD in): not permitted
Outgoing direct debit (SDD out): available on request
Outgoing SEPA standard, instant, or SWIFT transfer
API-driven flow management
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Frequently asked questions about the dedicated liquidity account

What is the difference between a dedicated liquidity account and a specially dedicated account (CAS)?

Both accounts segregate funds on behalf of an investment fund, but their scope differs. The dedicated liquidity account is used to hold the cash of a CIS (AIF or UCITS) under the supervision of a custodian, with no servicer generally involved in operations. The specially dedicated account (CAS) is designed for securitisation and structured finance arrangements, where a servicer operates the flows via API.


Find out more about our regulated client accounts


Who is the account holder for an AIF?

The AMC, acting as representative of the fund (on behalf of and for the fund). The amounts deposited are recorded off-balance sheet and do not belong to the AMC: they cannot be seized by its creditors in the event of failure.


Will the depositary bank accept that funds are held in Memo Bank's books?

Yes. Regulations allow the delegation of cash account keeping to a credit institution, under the depositary's oversight. We work with several depositaries in the Paris market. Memo Bank transmits a Swift MT940 file to the depositary on a daily basis, enabling it to fulfil its regulatory oversight obligations with full visibility over flows and balances.

Is a specific agreement required?

Yes. Depending on the complexity of the arrangement (with or without a delegate or custodian), a specific agreement must be signed. Memo Bank holds tried-and-tested contract templates approved by regulators, which significantly accelerates the set-up process.

Can deposits in the dedicated liquidity account be remunerated or invested?

Yes. Funds earn interest at 25% of the €STR by default. Unlike the specially dedicated account (CAS), cash in the dedicated liquidity account can also be transferred to a Booster account or invested in money market funds (MMFs) to optimise yield, provided the fund's rules permit it.

Can virtual IBANs be used for outgoing flows (dividends, redemptions)?

Yes. Memo Bank's virtual IBANs are bidirectional: they are used both to receive subscriptions (pay-in) and to redistribute dividends or process repayments back to the same investor (pay-out).

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Your flows ring-fenced, automated, managed in real time.

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