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TrueLayer Onboarding FAQ

1.   What agreement does a Codat customer need to sign?

All Codat customers would need to sign:

  • Codat’s customer agreement, which covers the customer’s relationship with Codat (TrueLayer will not see this)
  • A Joint Agreement between the customer, Codat and TrueLayer for the provision of Account Information Services (AIS) by TrueLayer

In addition, for any Codat customers that are (a) providing AIS to their end-users and (b) not regulated or authorised to provide AIS, they would also need to become an agent of TrueLayer by signing:

  • An AIS Agent Agreement between the customer and TrueLayer

2.  How would a Codat customer know whether they are providing AIS to their end-users?

The key factor here is whether the customer’s app or website will be displaying account information acquired through the TrueLayer’s Data API back to an end-user.  For example:

  • ✅ - customer’s app or website allows the end-user to view and categorise account transactions. This may either be consolidated data or simply their bank transactions.
  • ❌ - customer’s app or website is simply acquiring bank information to assist with internal decision making (e.g. KYC or credit analysis) without displaying this information back to an end-user.

TrueLayer has further information on this here.

Note that this is something TrueLayer can help assess as part of its due diligence process when onboarding Codat’s customers.  For example, TrueLayer will ask for screenshots of the customer’s app or website to assess whether AIS services are provided to the end-user at any point in the user experience.

That being said, it remains the customer’s responsibility to seek legal advice on whether they are providing AIS and, if so, whether they may be required to either become regulated themselves or become TrueLayer’s AIS agent.

3.  What does it mean to be TrueLayer’s AIS agent?

By becoming TrueLayer’s AIS agent, Codat’s customer does not need to become authorised or regulated to provide AIS - they can provide those services to their end-users by relying on TrueLayer’s own FCA AIS permissions

As an agent, Codat’s customer will be acting on behalf of TrueLayer in providing those AIS services, so TrueLayer will need to understand how those services will be delivered through the customer’s app or website.  The customer will also need to disclose the fact it is acting as TrueLayer’s agent to its end-users.

TrueLayer will charge a fee for these agency arrangements, as set out in the AIS Agent Agreement.

The customer should review the AIS Agent Agreement carefully and be comfortable with the obligations and requirements set out in the agreement.

The customer will also be registered as TrueLayer’s agent with the FCA and their details will appear on the FCA register entry for TrueLayer here.

4.  What is the due diligence process?

This would depend on the route the customer takes.

  • Data API (Non-Agent): TrueLayer will conduct a KYB check on the business entity using various data sources. We may also request a data flow diagram/screenshots of the customer's user journey.
  • AIS Agent Process: KYB check on the business entity, KYC check on the fit and proper, evidence of the companies system and controls, policy documents (listed in application form) and valid PII and Cyber insurance.

5.  Once the due diligence process has been completed, what steps / actions should Codat’s customer expect to go through as part of onboarding?

TrueLayer’s legal team will prepare a Joint Agreement and, if required, the AIS Agent Agreement for signature by relevant parties.  TrueLayer will require some basic corporate details, signatory details and contacts for notices from the customer to prepare the agreements for signature.  TrueLayer will typically ask for signatures via Docusign.

Once relevant agreements have been signed, the process then differs depending on which route Codat’s customer takes:

  • Data API (Non-Agent) process: the customer can expect to go straight to production after signing the Joint Agreement.
  • AIS Agent Process: when the Joint Agreement and AIS Agent Agreement has been signed, TrueLayer’s compliance team will submit an application to the FCA for the customer to become a PSD Agent of TrueLayer.

6.  How long does the onboarding process typically take, including KYC / KYB?

For non-agent customers, you can expect the customer to be onboarded and the Joint Agreement to be issued by TrueLayer within 3-4 business days. However, timing may differ depending on how complex a particular onboarding is and level of effort required to review the customer.

For agent customers, the onboarding period will be dependent on the amount of information the customer provides during the due diligence and PSD Agent application process. Once due diligence has passed and we have submitted a PSD Agent application, a response from the FCA generally takes up to 15 working days.

7.  What should we do if Codat customer has a question regarding the onboarding process?

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