Direct-Source Model
In the Direct-Source model, funds are placed into the (DDM Program) on a direct basis, meaning the Sending Institution, acting as agent of its Customer, places its Customer’s funds directly into the DDM Program. In this transaction, the Sending Institution enters into a Services Agreement with R&T.
This model centralizes flow-of-funds responsibility with the Sending Institution originating the deposits while R&T serves as the Administrator of the DDM Program, the DDM Program's designated institution serves as Custodian and Settlement Bank, an affiliate of R&T, Stable Custody Group II LLC acts as Sub-Custodian for the DDM Program.
This page outlines participant roles, eligibility requirements, allowable fund sources, and prohibited fund sources.
Roles and Responsibilities
Sending Institution
In the Direct-Source model, the Sending Institution is federally regulated and therefore:
- sends funds directly into the DDM Program.
- acts as the agent for its Customers.
- ensures customer eligibility and program compliance.
Administrator
See Administrator.
Settlement Bank, Custodian, and Sub-Custodian
See Settlement Bank, Custodian, and Sub-Custodian.
Receiving Institution
Sources of Funds
This section outlines the institutional requirements that must be met to originate funds into the DDM Program under the Direct-Source model.
Eligible Sources of Funds
Funds entering the DDM Program through the Direct-Source model must originate from one of the following institutions:
- Bank
- Bank Affiliated Trust Company/Federally Chartered Trust Company
- Credit Union
- BaaS FinTech
Ineligible Sources of Funds
- Independent Trust Company/State-Chartered Trust Company
- Broker Dealer*
*Broker-Dealers can only enter the DDM Program through the DDM-Indirect-Source-Sweep Program. Separately, R&T offers the RTID program, through which Broker-Dealers may participate in cash sweep programs.
Prohibited Fund Sources
R&T prohibits clients from placing or sweeping funds from the following sources into the DDM Program:
Marijuana-Related Businesses (MRBs)
Funds sourced directly or indirectly from a Marijuana-Related Business
Sanctioned Entities (OFAC)
Funds sourced directly or indirectly from:
- OFAC-designated Sanctioned Targets
- Sanctioned jurisdictions
Rules for Entering the Program
This section defines the requirements for institutions sending or receiving funds under the Direct-Source model, including regulatory constraints that affect eligibility.
Sending Institution Requirements
A Sending Institution must be one of the following:
- FDIC-insured bank or savings association, including trust departments of FDIC-insured institutions
- Federally Chartered Trust Company
- Credit Union
- Financial institution under the Bank Secrecy Act that:
- is subject to AML program requirement under 31 U.S.C. § 5318(h).
- falls under the Bank Secrecy Act and its implementing regulations.
- is supervised by a federal functional regulator (as defined in 31 C.F.R. § 1010.100(r)).
Receiving Institution Requirements
A Receiving Institution (acting as Receive-Only or Reciprocal Institution) must be:
- FDIC-insured bank or savings association
- a low-income designated credit union (LICU) and is eligible to accept non-member deposits1
1Receiving credit unions must be LICUs. The reason is that only LICUs are permitted to receive non-member funds.
What's Next
- Explore DDM's Participation Options to see how a Direct-Source participant chooses between Send-Only or Reciprocal participation.
Updated 9 days ago
