Whether you are a seasoned neobank that already offers debit or charge cards to consumers, or you are building a brand new bill pay app from scratch, using Column's banking rails and account structure offers several key advantages over traditional legacy banking partners. This overview page will give a brief overview of our data model, walk through some of the benefits our data model offers.

System of record

One of riskiest and most labor intensive aspects of managing a typical Legacy Commingled FBO account is keeping the system of record for all of your users' accounts. By system of record we are referring to:

• Account balances (present and historical)
• Historical transfers (Book, Wire, ACH, ACH Returns)

Because Column's data structure is more granular than a Commingled FBO Account, Column is able to maintain the system of record for each of your users. Under the hood, each of your users will have their own account at Column. Legally, you will own these accounts for the benefit of your user. Because each user has their own account, Column can keep track of all your users' account balances and historical transfers, and make all information easily available via API or downloadable .csv files.

ACH returns automation

Each Customer FBO account at Column has a dedicated account number. Because of this, Column is able to originate ACH transfers to the Fed using a customer specific account number. If these ACH's are returned, funds are automatically credited or debited to the customer account directly.

On the flip side, when Column receives ACH transfers from other banks, we file many of the most common return codes (e.g. R01 — NSF) automatically for you..

Transaction monitoring

With Commingled FBO accounts, fintechs are responsible for doing their own transaction monitoring. By transaction monitoring we mean:

• Anti-money laundering
• Ongoing Sanctions/OFAC checks

Column handles transaction monitoring on behalf of our parter platforms. Column runs OFAC and Sanctions checks on all incoming and outgoing transactions, as well as automatically monitors and flags suspicious transactions patterns which are indicators of money laundering.

Audit / reconciliation

With Legacy Commingled FBOs its up to the fintech partner to come up with their own process for how to provide their users with statements, or how to provide data to auditors. Using Column's FBO account structure, we automate most of this manual process for you.

Column will provide you downloadable reports in .csv format which can show

• Balances for all your user accounts at any given point in time (present or historical).
• A complete list of transfers (ACH, Book, Wire for all your users' accounts across any time period).

Direct connection with the Federal Reserve

Unlike many other bank sponsors who use layers of middleware to connect to the Federal Reserve for Wires and ACH transfers, Column has its own direct connection to the Fed. We expose this direct connection to our partners, and pass on the benefits of a direct connection to our partners. Specific benefits include:

• Access to all Fed settlement windows for ACH transfers.
• Access to full breadth of ACH transfer data from Fed.
• Access to full Fedwire uptime for wire transfers.
• Access to full breadth of wire data from Fed.
• Receive webhook events each time a transfer is updated by the Fed.