Key takeaways
- A payment group with entities in several countries reports customer-money positions to several regulators, each on its own schedule.
- The main reports include the UK monthly safeguarding return, the US quarterly MSB call report, Canada's RPAA reports and stablecoin reserve reports.
- Every reported figure should come from the same reconciled daily records, with its source noted in the calendar.
- A shared calendar owned by one person prevents missed deadlines and inconsistent figures.
Why a calendar matters
Missed or inconsistent regulatory reports are among the most avoidable problems a payment group faces. Each regulator sets its own deadlines and formats, and each report draws on figures that may also appear in other reports. When reports are prepared by different teams in different countries, the same figure can be reported differently to two regulators, or a deadline can slip because no one owned it.
The risk grows with each new licence. A group that adds a Canadian entity or a stablecoin product adds new reports, new deadlines and new figures, often handled by people who have not met the team responsible for the UK return or the US call report.
A single calendar solves both problems. It lists every customer-money report the group files, its frequency and deadline, the entity it covers, who prepares and approves it, and where each figure comes from.
Keep the calendar in a shared location, set reminders well before each deadline, and record each submission once it is filed. The calendar is also the starting point for any regulatory change: when a regulator changes a form or a deadline, the calendar shows who needs to know.
The main customer-money reports
The table lists the principal reports for a group operating across the main markets. Firms should confirm current deadlines with each regulator, as forms and dates change.
| Jurisdiction | Report | Frequency | Deadline | Source of figures |
|---|---|---|---|---|
| United Kingdom | Safeguarding return (REP027) | Monthly | 15 business days after month end | Daily CASS 15 reconciliations |
| United Kingdom | Safeguarding audit report | Annual | Set by SUP 3A after period end | Year of reconciliation records |
| United States | NMLS MSB Call Report | Quarterly | After each quarter end, per NMLS schedule | Daily permissible investment history |
| United States | GENIUS Act reserve report (stablecoin issuers) | Monthly | Published monthly, with CEO and CFO certification | Daily reserve reconciliation |
| Canada | RPAA annual report | Annual | Per Bank of Canada schedule | Safeguarding records and account register |
| Canada | RPAA significant change notices | Event-driven | Before the change takes effect | Account and arrangement register |
| European Union | National safeguarding reporting | Varies by supervisor | Varies | Daily entity reconciliations |
| Hong Kong | Stablecoin reserve audits and reporting | Periodic | As set by the HKMA | Daily reserve reconciliation |
Sourcing every figure from one place
The most important column in the calendar is the last one. Every figure in every report should trace back to the same reconciled daily records. If the UK return, the board pack and the audit all draw on the same CASS 15 reconciliations, they will agree. If the US call report draws on the same daily permissible investment history the treasury team uses, it will survive an examiner's test of a random date.
Our guides to REP027, the MSB call report, RPAA reporting and the GENIUS Act monthly report explain each report in detail.
Ownership and review
Give the calendar one owner, usually in group compliance or finance, with a named preparer and approver for each report. Review it quarterly and whenever the group adds an entity, a licence or a product. Record each submission with the date, the version filed and the source data used, so the group can answer any regulator question later without rebuilding the figures.
The calendar is also a useful document for the board. A one-page summary of every regulator, every report, its status and any late or corrected submissions gives directors a clear view of the group's regulatory standing without reading each report.
Safeheld produces the reconciled daily records every one of these reports depends on, by entity and jurisdiction. See regulatory reporting software and safeguarding rules compared.
Frequently asked questions
What regulatory reports do payment groups file?
Typically the UK monthly safeguarding return and annual audit, the US quarterly MSB call report, Canada's RPAA reports, EU national reporting and, for stablecoin issuers, reserve reports.
When is the UK safeguarding return due?
Within 15 business days after each month end.
How can groups keep reports consistent?
By sourcing every figure from the same reconciled daily records and noting the source in a shared calendar.
Who should own the reporting calendar?
One person in group compliance or finance, with a named preparer and approver for each report.
References
- FCA, PS25/12: Changes to the safeguarding regime for payments and e-money firms
- Massachusetts General Laws c.169B §9: permissible investments
- Directive (EU) 2015/2366 (PSD2)
- Bank of Canada, Retail payment supervision
- Payment Services Act 2019 (Singapore)
- Payment Systems and Stored Value Facilities Ordinance (Cap. 584)
About Safeheld
Safeheld reconciles client money every day, resolves every difference and prepares every regulatory return for sign-off, for regulated firms in the United States, the United Kingdom, the European Union, Canada, Australia, Singapore and Hong Kong. To discuss your operations, contact us at safeheld.com/contact.
This article is for general information and does not constitute legal or regulatory advice.