custody · subject to CMF authorization

Custody of financial instruments, with the rules built in.

Custodian SpA has one exclusive corporate purpose: the custody of financial instruments under Law No. 21,521. Once the Comisión para el Mercado Financiero (CMF) grants authorization, each client will have its own custody account. Its instruments will sit in wallets segregated from Custodian's, with a custody register it will be able to consult.

Today Custodian SpA holds no third-party instruments. See regulatory status ↓

what it is · Law No. 21,521, art. 3 No. 5

Custody is holding instruments on someone else's behalf.

«To hold, in its own name on behalf of third parties, or in their name, financial instruments, money or currencies arising from the flows or the disposal of financial instruments held in custody, or delivered by them to acquire financial instruments or to secure transactions in those instruments.»

Law No. 21,521, article 3 No. 5. Unofficial translation; the Spanish text governs.

Under the law, custody is one of the technology-based financial services (art. 2 letter d). To provide it, an entity such as Custodian SpA must register in the Registry of Financial Service Providers and obtain CMF authorization for that service.

who it is for

Two sides of one register.

issuers

Fund managers and PE managers

General fund managers (AGF) and private equity managers. Once the CMF grants authorization, their funds will be able to issue instruments in a programmable digital format with our technology and deliver them into custody.

holders

Limited partners

The investors in those funds, who hold the instruments. Once custody is authorized, they will see their positions and movements in their custody account.

which instruments · art. 3 No. 8

What we will hold in custody.

  • Financial instruments (Law No. 21,521, art. 3 No. 8): units of private investment funds and other securities not registered in the CMF Securities Registry or Foreign Securities Registry, in a programmable digital format.
  • In addition, as part of custody (art. 3 No. 5) and not as a financial instrument: money or currencies, only when they arise from instruments in custody or are delivered to acquire them or secure their transactions.

Out of scope: publicly offered securities, and money or currencies on their own, which the law excludes from the definition of financial instrument.

how we will hold custody

Six controls, to be written into the infrastructure.

This is how the service will work once the CMF grants authorization.

01

Segregated accounts and wallets

Each client will have its own custody account, in wallets separate from Custodian's. Its instruments will not be reused or lent without its consent (CMF General Rule No. 502, section IV.E.3.1 i) 3)), or be seized for Custodian's debts (Law No. 21,521, art. 11).

02

Safeguarded keys

Our custody policy will set out how we will safeguard the private cryptographic keys of custody wallets.

03

Custody register and reconciliation

We will record every transaction, position, transfer, reconciliation and change in key custody, and reconcile the register periodically against the chains and the accounts.

04

Client access

Our custody policy will set out the client's means of access to its financial instruments and private cryptographic keys. The client will consult its custody register and instruct withdrawals or transfers under its agreement.

05

Rights on instruction

We will vote, collect flows and exercise other rights attached to instruments in custody only on the client's instruction.

06

Controls before finality

Every transfer between custody accounts will be verified before it becomes final.

what it is not

Custody, and nothing else.

  • Not issuance: the fund or its manager issues; once the CMF grants authorization, Custodian will hold the instruments in custody and provide the issuance technology as an activity inherent to custody (CMF General Rule No. 502, section VII letter f).
  • Not brokerage: we do not offer instruments to investors or execute orders for third parties.
  • Not investment advice: we do not recommend instruments or transactions.
  • Not a trading venue: we operate no markets or trading platforms.
  • Not a payment service: we will hold money or currencies only when they arise from instruments in custody or are delivered to acquire them or secure their transactions (Law No. 21,521, art. 3 No. 5).
  • We do not manage third-party funds or portfolios.
regulatory status

Where we stand today.

Custodian SpA is not registered in the CMF Registry of Financial Service Providers and is not authorized to provide services under Law No. 21,521. It is preparing its application for registration and for authorization to provide custody of financial instruments. Until authorized, it holds no third-party instruments. The platform runs in pilot with Custodian's own resources and test instruments only.

You can check this in the Registry of Financial Service Providers at www.cmfchile.cl.

information disclosure

Information disclosure

To be published once authorization is obtained and kept up to date.

  • Services authorized by the CMF (Law No. 21,521, art. 5).
  • Fee structure: whether we charge for storing keys, documentation or instruments; whether the fee is fixed or variable; its amount or percentage, and how it is determined.
  • Conflicts of interest arising from our business model or sources of income, and how we manage them.
  • Operational risk management policies and committed service levels for availability, performance and continuity.
  • How and when we will report incidents that compromise the availability and security of information.
  • Guarantees posted to compensate clients for damages (Law No. 21,521, art. 10) and how they are enforced and allocated.
  • Pending matters that could materially compromise our solvency, liquidity or ability to meet our obligations.

Does your fund issue digital instruments? Let's talk about custody.

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