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It's a good thing, not a bad thing, that they have a separate line item on their balance sheet for funds held for customers. It means that they are not aggrega
by legutierr 5y ago
It's a good thing, not a bad thing, that they have a separate line item on their balance sheet for funds held for customers. It means that they are not aggregating customer funds with the company's own cash.
Also, there is a precisely equal line item on the liabilities side showing "customer fund deposits". This is exactly what you would want to see if they were accounting for things properly.
This is not an attempt by the company to misappropriate customer funds. Bill.com is a money transmitter, and as such they are obligated to hold their customer funds in trust. This is one of the things that the state banking regulators that regulate money transmitters look at closely when they conduct periodic on-site examinations. If they tried to misappropriate customer funds, it would be detected within the year and they would be shut down.
Bill.com isn't acting as a bank here, but is instead switching over to a standard practice followed by money transmitters such as PayPal and Cashapp, etc., which is to maintain customer funds in their own trust accounts on their own balance sheets, and only forward those funds onwards to third-party banks when explicitly requested to do so by their customers.
Why would Bill.com do this? It's because interest rates are going up, and 3% annual interest on $3.3 billion is $100 million. If they can hold this money on their own balance sheet (and most likely invest it in US treasuries), then they can improve their profitability. By forwarding cash immediately to third-party banks, they had previously been leaving a lot of money on the table.
For what its worth, money transmitter regulations do place restrictions on how entities are permitted to invest customer funds held in trust. They can keep that money in bank accounts, but they can also invest those funds in US treasuries; the permitted investments are explicitly enumerated in the regulations. Again, this is one of the things that banking regulators look at closely when examining companies like this.
Is it a good thing that Bill.com did this, from their customers' perspective? Probably not. To the extent that their customers' might have earned interest on these funds had they been deposited into their bank accounts sooner, Bill.com is depriving their customers of interest income. As the company's email admits, customers should have been informed of this change well in advance of when it was to occur, to be given the chance to switch providers if they didn't like the new terms.
That being said, no one here is stealing anybody's money, and most likely no laws are being broken (unless they broke the law by delaying notification).
- chmod775 5y ago> It's a good thing, not a bad thing, that they have a separate line item on their balance sheet for funds held for customers. That is not what Animats was saying. They were talking about that showing up on a balance sheet at all, not whether it is separate vs combined with something else.
- legutierr 5y agoIf they are holding onto customer funds, then you definitely want it to show up on the balance sheet. Are you saying they shouldn't be holding onto customer funds at all? If you disagree with their doing this on a moral or ethical level, then that is your prerogative, but they don't seem to be doing anything unusual or untoward.
- chmod775 5y ago> Are you saying they shouldn't be holding onto customer funds at all? No. I pointed out that you assumed Animats said something that they in fact didn't. I have no opinion on what Bill.com should or should not be doing.
- Animats 5y agoThat's possible. Bill.com is licensed as a money transmitter in California.[1] The funds are supposed to be in a trust account, with Bill.com acting as a fiduciary. It's important to be sure that's actually the case. This really matters if Bill.com goes bankrupt. If the funds are in a trust account, you get them back, reasonably quickly. Otherwise... But see [2], regarding the "Agent of a payee exception to California money transmitter law". "The question of whether the agent-of-a-payee exemption applies is of considerable importance for any platform involved in facilitating payments ─ including consumer marketplace platforms, billing services, payment facilitators and other payment processors, and business-to-business (B2B) payments platforms." Money transmitters are regulated primarily for consumer protection purposes. Businesses are expected to take measures to protect themselves. Large customers of Bill.com really need to nail down exactly who owns that money. [1] https://dfpi.ca.gov/2018/06/05/bill-com/ https://dfpi.ca.gov/2018/06/05/bill-com/ [2] https://www.jdsupra.com/legalnews/alert-california-finalizes-rulemaking-7751931/ https://www.jdsupra.com/legalnews/alert-california-finalizes...