Decision / Product
Launching a customer wallet
Does giving customers a balance change what we are doing?
A wallet looks like a feature. Regulatorily it is often a change in the character of the activity, because the institution begins holding something on the customer's behalf.
The design choices — balance or claim, who holds funds, whether value can be transferred to third parties — determine how far the position moves.
Regulatory delta
What this decision tends to move
The delta is the difference between the institution's position today and its position if this decision were executed.
- Activity
- Whether holding value changes the activity itself.
- Safeguarding
- How customer funds must be treated.
- Permissions
- Whether the current permission set still fits.
- State exposure
- Where balances create state-level scope.
- Controls
- What the operating model must demonstrate.
Design space
Ways to reach the same commercial objective
Two configurations that achieve the same outcome frequently produce materially different regulatory deltas. Comparing them is how the decision is made.
Option 01
Stored balance held by the institution
Largest change to position.
Option 02
Balance held at a partner bank
Moves consequence into the dependency.
Option 03
Claim against a completed transaction only
Often the smallest delta.
Before committing
What management should establish first
- Whether the wallet is a balance or a claim, in substance
- Whether third-party transfer is in scope
- What safeguarding the chosen model implies
Common questions
Questions this page answers
Does a wallet always require new permissions?
Not always. Substance matters more than the label — what the customer holds and who holds it drive the answer.
Related decisions