Bank due diligence process
Latest update: November 9, 2023
By: The Flourish Cash team
Below is an overview of the Flourish Cash1 Program Bank Network, Flourish’s Bank Risk Committee, our bank due diligence and risk monitoring process, and Program Bank opt-out functionality.
The Flourish Cash bank network
Flourish Cash is offered through Flourish Financial LLC, an SEC registered broker-dealer and FINRA member. Flourish Cash operates by spreading customer deposits across a curated network of FDIC-member banks with whom we’ve created partnerships – our Program Banks. This approach allows us to provide clients with increased rates and significantly higher FDIC insurance coverage than a typical checking or savings account.
We believe that this structure is a powerful way to ensure the safety of our customers’ funds. We can spread funds across multiple banks – we currently offer up to 16x the FDIC insurance coverage of a typical bank2 – and can rapidly allocate funds away from or to a given bank if the need arises.
This structure also allows us to provide clients with competitive rates. As of September 7, clients earn up to 5.00% APY on balances up to $500,000 in an individual or business account or up to $1,000,000 in a joint account – 10x the national average3 – with additional funds earning 4.50% APY.4 At the same time, clients have easy access to their funds, with an unlimited number of withdrawals each month.
While the health of each underlying bank is important, there is far greater strength in the network as a whole. As such, we have worked diligently to build a robust, diversified network of FDIC-member banks that we continue to expand and strengthen to this day.
Program Bank due diligence process
We are committed to ongoing, rigorous, and in-depth reviews of all our Program Banks, balancing both quantitative and qualitative factors to ensure the safety and security of our customers’ funds.
Bank Risk Committee
To oversee our network of Program Banks, Flourish has an established Bank Risk Committee. This Committee includes the CEO and key members of Flourish’s management team. The Committee is ultimately responsible for reviewing and approving our Program Banks, and monitoring the overall safety of the Program Bank network.
Upfront and ongoing review
We conduct regular diligence on our Program Banks, both upfront and once they’ve joined the program.
- New banks: Our assessment starts in advance of a bank joining the program. We conduct a thorough upfront diligence process, assessing a number of qualitative and quantitative factors, before deciding whether and how to incorporate the new bank into our program.
- Quarterly review: On a quarterly basis, our Bank Risk Committee meets to re-evaluate qualitative and quantitative risk factors for all of our Program Banks.
- Ad hoc review: Our Bank Risk Committee conducts adhoc reviews when circumstances warrant additional due diligence, such as times of enhanced stress on the banking system. This may be general diligence conducted across all of our banks, or may be specific questions posed to a specific bank regarding potential idiosyncratic risk.
Risk monitoring factors
While our Bank Risk Committee regularly updates our overall risk monitoring factors as circumstances change, some of the factors we regularly review are detailed below.
- FDIC insured: We only partner with Program Banks which are members of the Federal Deposit Insurance Corporation (FDIC), an independent agency of the U.S. government established to protect deposits in American banks. By holding insured cash in FDIC-member banks, clients’ holdings are explicitly backed by the U.S. government. The majority of the balances in Flourish Cash are fully-FDIC insured. When we have uninsured balances (i.e., if a client deposits more funds than the FDIC insurance limit we can provide), those funds are currently placed at either Citibank, PNC, or HSBC, the three largest banks in our program. Since 1933, no depositor has ever lost a penny of FDIC-insured funds.5
- Balance Sheet Health Review: Leveraging data from quarterly FDIC call reports and public filings, we review various metrics to evaluate each bank’s balance sheet health and capitalization levels, including tier 1 capital and leverage ratios.
- Bank Communication: Flourish maintains ongoing dialogue with senior executives from each Program Bank. Meetings typically include Treasurers, Heads of Treasury Management, and Heads of Wholesale Funding, among others.
- Operational Sophistication: Each Program Bank must demonstrate a certain level of operational sophistication in order to participate in our Program. We have a series of test tasks that we perform prior to onboarding a bank to ensure competencies, such as speed of wire processing and robustness of reporting.
- Cybersecurity Risk: Using private risk monitoring tools, we evaluate each bank’s cyber risk and overall security posture and take a deep, investigative dive into any recent events.
- Reputational Risk: We monitor news and media related to all Program Banks in order to monitor reputation risk, including media coverage that could inform fluctuations and changes to stock prices, market capitalization, and more.
- Concentration Risk: We actively distribute deposits across the Program Banks in order to ensure they are spread out and diversified to avoid the risk that comes with too many deposits concentrated in one place. This gives us flexibility to shift funds quickly if needed and re-allocate to another bank with no disruption to clients.
- Credit Rating: Of the banks with credit ratings, Flourish only works with those that have been issued an investment grade credit rating from either Moody’s or Fitch. We continuously monitor any changes to bank ratings.
Current Program BanksAs of October 20, 2023, the following Program Banks are in the Flourish Cash program. All of our Program Banks continue to pass our routine and enhanced bank monitoring:
- Associated Bank
- Banc of California
- Bell Bank
- CIBC U.S.
- Citibank, N.A.
- East West Bank
- First Horizon Bank
- Flagstar Bank
- HSBC Bank USA
- KeyBank, N.A.
- Northbrook Bank & Trust
- PNC Bank
- Synovus Bank
- Third Coast Bank
- TriState Capital Bank
- U.S. Bank
- Webster Bank
Recent events in the banking industry have demonstrated that facts on the ground can change quickly. While diligence is certainly important, we believe that adding additional banks to our Bank Network is arguably the most important step we can take to enhance the security of the program overall. We’ve welcomed nine banks to the Flourish Cash program since January, which has provided us with increased capacity and the ability to offer clients even higher amounts of FDIC insurance coverage.
Commitment to transparency and opt-out functionality
Flourish aims to provide transparency about our current Program Banks and makes it extremely simple for clients to opt out of having their funds deposited at any of our underlying Program Banks.
Transparency into Program Banks: The complete list of Flourish Cash Program Banks is always available here. Flourish provides the complete list of Program Banks in writing to customers during the sign-up process.
In addition, customers receive a monthly statement that details which Program Bank(s) are holding their cash, and they are free to call our support team at any time to request this information.
Bank Opt-out functionality: During the sign-up process and at any point thereafter, customers can easily opt out of having their funds deposited at any particular Program Bank(s) by clicking a single checkbox. The amount of FDIC insurance coverage that is available to clients based on their opt-out settings is dynamically displayed on the page.
Looking forward, we will continue to strengthen our network of Program Banks, continue to ensure the safety of customer funds, and continue to communicate transparently. As always, please let us know if there is anything we can do to assist.
Flourish builds technology that empowers financial advisors, improves financial lives and retirement outcomes, and delivers new and innovative investment options to advisors. Today, the Flourish platform is used by more than 650 wealth management firms representing more than $1.5 trillion in assets under management. Flourish is wholly-owned by MassMutual. For more information, visit www.flourish.com.