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

See Receiving Institutions.

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.

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