Asset Managers & FinTech Companies Registration Guidebook
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(Prepared based on page 2 of the Financial Services Agency materials for the 8th Data Logistics Environment Research sales proceeds into its funds transfer service account) receives multiple payments of less than 1 million yen each from different people. In such case, "pursuant to the provisions of Cabinet Office Order, it is required to take measures to not hold user funds that will not be used for exchange transactions" (Article 51 of PSA). Specifically, if a user has funds in their account in excess of the transaction limit (1 million yen), then a Type 2 Funds Transfer Service Provider is to take measures to confirm the relationship between the user funds and exchange transactions, and if the probability that the funds will be used for a remittance is found to be low (determined by comprehensive consideration of (i) the amount of funds, (ii) period of the funds being retained in the account, (iii) previous remittances, and (iv) purpose of use), then it is necessary to request that the funds be paid out (Article 30-2 of the Funds Transfer Services Business Order). Type 3 Funds Transfer Service Provider A Type 3 Funds Transfer Service Provider can only conduct remittances of up to 50,000 yen per transaction (Article 12-2(2) of the PSA Enforcement Order). A Type 3 Funds Transfer Service is limited to 50,000 yen both per transaction (remittance amount) and per user (deposited amount) (Act 51-3 of PSA, Article 17-2 of the PSA Enforcement Order). For this reason, in the case of B to C remittances and C to B remittances (where the recipient receives sales proceeds into its funds transfer service account), user funds cannot be received into the account in excess of the 50,000 yen limit. A Type 3 Funds Transfer Service Provider can preserve user funds by managing deposits separately from its own assets (Article 45-2 of PSA), which is expected in order to reduce the cash-flow burden and costs. Group "Working Group on the Use of Data in the Age of AI and IoT", held on January 27, 2017) c. Example Open API Structure 56

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