Because of the unique nature of our online business and the fact that most of it is conducted with little contact with our clients, the Upper Deposit Limit (UDL) is a mechanism EasyEquities has devised to enable us to meet our ongoing customer due diligence (CDD) requirements per Section 21C of the FIC Act.
The UDL mechanism alerts us when the investment activity on a client account differs (based on the information the client has provided to us) from what we expect.
Once triggered, the mechanism notifies the client, requests information and places certain limitations on the client's investment activity until the required documentation has been received.
Once received, information on the client account is updated and he / she can continue investing without disruption.
How does the Upper Deposit Limit (UDL) work?
We use the "Earnings Status" you capture on registration to allocate you an Initial Upper Deposit Limit as per the table below:
Current Earnings Status
Initial Upper Deposit Limit
Private Sector Employment
Public Sector Employment
Self-employed / Consultant / Entrepreneur
As soon as you start funding your account, we keep a tally of the value of the total deposits made across all your accounts (ZAR, TFSA, USD (in rand equivalent), RA etc) in a rolling year (365 days).
On the day a new deposit causes the value of your total deposits in the last 365 days to be greater than your UDL:
1. We notify you of the breach and request the documents / information listed below.
2. The system puts a hold on your ability to make any withdrawals and a clock starts running.
3. If the required information is not submitted within 30 days of notification, any further deposits will NOT be made available for investment until the required information has been received, but will be allocated instead to a special interest-bearing account on the platform.
These "uncleared deposits" will be visible to you on your account overview page (as highlighted in yellow in the image below) and the value reflected in your NAV but the funds cannot be invested until we've obtained further information.
When the required documentation / information has been received, our client engagement team can either:
1. Increase the Upper Deposit Limit - We can reset the Initial UDL created on registration to 20% of proven consistent regular income (eg. salary, rental income, dividends from investments etc), OR
2. Verify any irregular / out-of-the-ordinary deposits (eg. bonus, inheritance, proceeds from sales of assets etc)
Once the type and value of an individual irregular deposit are verified, the value of that verified deposit is no longer included in the calculation of total cumulative deposits in a rolling year.
What would I need to send you?
Please email one of the documents listed below to firstname.lastname@example.org, so that we can evaluate a possible increase to your UDL, verify an individual irregular deposit or work closely together with you to reset the rules according to how you plan to invest:
- Copy of IRP5 (no older than the previous tax year)
- Copy of a payslip (no older than 3 months old)
- Copy of minimum of two (2) months bank statements (no older than 3 months old)
- Any other 'formal' documents that may be able to prove your earnings to us
If the deposit is a larger than normal sum and of an irregular nature (e.g. a bonus, inheritance, commission, proceeds on sale of assets) you can also email documentary evidence of that particular deposit to us so that we can take that into account too.
- This is not meant to be an onerous or difficult process, but rather a consultative one in which we have a chat, get to know you a bit better and update some of your information.
- We assure you that we will safeguard the security, integrity, and confidentiality of any information sent to us as we are required to do as an authorised FSP and in terms of the Protection of Personal Information Act, 2013.
Should you notice a deposit is Uncleared and haven't been contacted yet, or have any questions / concerns with regard to the operation of our UDL, please call into our Client Service department on the usual number + 27 (0)87 940 6106 stating that you have an Uncleared Deposit or want to talk about your UDL so that an agent can help you immediately.