Correspondence 0000950170-24-004390 from Paysafe Ltd (PSFE, PSFE-WT) (CIK 0001833835) (PSFE)
Paysafe Ltd (PSFE, PSFE-WT) (CIK 0001833835)
Date: Jan. 16, 2024 · CIK: 0001833835 · Accession: 0000950170-24-004390
AI Filing Summary & Sentiment
File numbers found in text: 001-40302
Referenced dates: December 7, 2023, November 14, 2023
Letter
Division of Corporate Finance Office of Trade & Services United States Securities and Exchange Commission Re: Paysafe Limited Form 20-F for the Fiscal Year Ended December 31, 2022 Form 6-K filed November 14, 2023 File No. 001-40302
Dear Ms. Rhodes and Mr. Decker:
On behalf of Paysafe Limited (the “Company,” “Paysafe,” “we,” or “us”), we hereby submit this letter in response to comments contained in the letter of the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission dated December 7, 2023 (the “Comment Letter”) related to the Company’s Form 20-F for the fiscal year ended December 31, 2022 and the Form 6-K filed November 14, 2023. For the convenience of the Staff, for each of the Staff’s comments, we have repeated the text of the comment below in bold text and followed the comment with the Company’s response. Attached as Exhibit A to this letter is a copy of the earnings release dated November 14, 2023, marked to show the approach we intend to take in our future earnings releases in response to the comments in the Comment Letter. Additions are shown in underline and deletions are marked as strikethrough.
Form 20-F for the Fiscal Year Ended December 31, 2022
Financial Statements
Consolidated Statements of Comprehensive Loss, page F-5
1.Please disclose the earnings per share information for each period presented on the face of your statements of comprehensive loss. Refer to ASC 260-10-45-2.
Basic and diluted earnings per share for the periods ended December 31, 2022, 2021 and 2020 were ($30.78), ($1.84) and ($2.10), respectively. The Company acknowledges that these amounts were included in Note 3 of the financial statements in the prior years rather than the face of the financial statements.
Paysafe began including earnings per share information in its interim unaudited consolidated statements of comprehensive loss, starting with the interim period ended March 31, 2023 filed on Form 6-K on May 16, 2023, in order to comply with ASC 260-10-45-2. The Form 20-F for the fiscal year ended December 31, 2023, the earnings release for the quarter ending December 31,
2023 to be furnished on Form 6-K and future filings will also include earnings per share information for each period on the face of the consolidated statement of comprehensive loss.
Consolidated Statements of Cash Flows, page F-10
2.Please tell us and disclose whether funds payable and amounts due to customers are amounts that must be refunded to the customer or remitted to a third party. Also, tell us how you determined an increase in funds payable and amounts due to customers is an operating cash inflow, rather than a financing cash inflow that is more akin to a borrowing. In addition, tell us how you determined a decrease in funds payable and amounts due to customers is an operating cash outflow, rather than a financing cash outflow. Refer to ASCs 230-10-45-16(a), 230-10-45-17(f), 230-10-45-14(b) and 230-10- 45-15(b).
Mainly within our Digital Wallets segment, the funds from the customer to the merchant flow through Paysafe. We refer to this as “in the flow of funds” as Paysafe holds these funds in our own bank accounts on behalf of the customer, until they are due to a merchant. The liability is to the customer for funds held on behalf of the customer (i.e., wallet/voucher balances) prior to being used. The wallet/voucher balances can be used with a merchant at any time by the customer holding the wallet or voucher. If the customer holds a wallet, these funds can also be withdrawn at any time. A liability becomes due to the merchant when the customer uses the wallet or voucher to make a purchase from the merchant. In the remainder of our Digital Wallets segment, and when we are in the flow of funds within our Merchant Solutions segment, this represents funds owed to the merchants for transactions processed by Paysafe. The Company will revise the funds payable and amounts due to customers disclosure in Note 1 of the FY 2023 Form 20-F to provide greater detail regarding the nature and types of amounts included in this account. The revised disclosure to be prospectively included in Note 1 is as follows:
i.Note 1: Funds Payable and Amounts Due to Customers
When electronic money (“e-money”) is issued, the Company recognizes a liability upon the issuance of e-money to its customers and merchants to the customer equal to the amount of electronic e-money that has been issued. The liability is due to the customer prior to the funds being used.
In addition, where the Company is in the flow of funds in the transaction settlement cycle, a liability is recognized for the amount to be settled to merchants owed to the merchants. A majority of these transactions are net settled, whereby the amounts due to merchants are settled net of the revenue transaction fees owed by the merchant.
These liabilities are presented as “Funds payable and amounts due to customers” in the Company’s Consolidated Statements of Financial Position.
Within our core Digital Wallets business (Digital Wallets segment), when the customer deposits e-money into its wallet, Paysafe records a liability for the “Funds payable and amounts due to customers” and the funds are recorded as “Customer accounts and other restricted cash, net” (or “Settlement receivables, net” for funds in transit). As a licensed e-money issuer Paysafe has the obligation to store, safeguard and process transactions on behalf of its clients. When the customer initiates a transaction (i.e. deposits funds using a payment service provider, makes a purchase from a merchant, etc.), Paysafe recognizes revenue related to digital wallet services and cost of services
to the payment service provider that processed the transaction. When we settle with the payment service provider, we settle net of the fees owed which is recorded against “Settlement receivables, net.”
Within our eCash business (Digital Wallets segment), when the customer purchases a voucher, Paysafe records a liability for “Funds payable and amounts due to the customer” and a cost of sale to the distributor that processed the transaction on behalf of Paysafe. For the majority of transactions, the funds we receive from the distributors are net of these costs. Before receipt, these funds are recorded as “Settlement receivables, net,” and following receipt, these funds are reclassified to “Customer accounts and other restricted cash, net.” When the customer uses its voucher with a merchant, Paysafe recognizes revenue from the merchant for providing digital wallet services related to that transaction and funds payable becomes due to the merchant. When we settle with the merchant, we settle net of this revenue for the majority of the transactions.
Within our Merchant Solutions segment, when we are in the flow of funds in the transaction settlement cycle, a liability for “Funds payable and amounts due to customers” is recognized for the amount to be settled to merchants, net of revenue recognized for the payment processing services provided. Concurrently, “Settlement receivables, net” and cost of services is recorded. The funds flow through the Company and to the merchant after the transaction has occurred which is recorded in “Customer accounts and other restricted cash, net”. A majority of these transactions are net settled, whereby the amounts due to merchants are settled net of the revenue transaction fees owed by the merchant.
Based on the above net settlement process, settlement receivables and funds payable and amounts due to customers are similar to trade receivables and trade payables which are considered working capital movements as the balances are directly related to revenue and cost of sales and the cash flow movements are directly related to our operations.
In determining that the change in funds payable and amounts due to customers is an operating cash flow, rather than a financing cash flow, we considered the definitions of “financing activities” and “operating activities” in ASC 230-10-20, the examples of cash inflows from financing activities in ASC 230-10-45-14 and cash outflows for financing activities in ASC 230-10-45-15, and the examples of cash inflows from operating activities in ASC 230-10-45-16 and cash outflows for operating activities in ASC 230-10-45-17. As described in further detail above, these cash flows directly stem from activities that relate to providing services and the cash effects of transactions that enter into the determination of net income. We view the collection of the cash from the customer, and remittance to the customer or merchant to be part of the cash flow directly related to providing our digital wallet and payment processing services and generating revenue in accordance with ASC 230-10-45-16. As such, we believe the presentation within operating for the “funds payable to a customer” is appropriate as the Company views the collection and remittance of funds to be an integral part of providing its service offering.
While the Company believes its policy of presenting the funds payable activity within operating is appropriate and acceptable, the Company also acknowledges that another acceptable presentation alternative could be to present such activity within financing activities. The technical argument supporting financing is to view the collection of funds from the customer as akin to a borrowing, consistent with ASC 230-10-45-14.b. Likewise, the settlement of the funds payable to a customer could be viewed as a “repayment of amounts borrowed” in accordance with ASC 230-10-45-15.b.
Notwithstanding the alternative view of financing presentation, the Company believes that presentation within operating is also acceptable for the reasons outlined above. We further believe
that, in substance, the cash flow associated with funds payable is more akin to an operating activity as the funds are obtained for purposes of earning revenue as opposed to raising capital. As such, we believe continued presentation within operating for future filings is appropriate.
3.Please tell us and disclose in greater detail the nature and types of amounts included in customer accounts and other restricted cash, net. Quantify the different types of amounts. Also, tell us how you determined you have control over the amounts included in customer accounts and other restricted cash, net, including whether you (a) have the ability to direct how and when the funds would be used, (b) have physical possession of the funds and/or (c) hold the funds in a bank account in your name and you can transact in this account at any time. Refer to ASCs 230-10-50-7 and 230-10-45-4, Rule 5-02(1) of Regulation S-X and BC9 in ASU 2016-18.
As part of the settlement cycle, the Company receives customer funds either in exchange for electronic money (“e-money”) issued or within the transaction settlement cycle to merchants. The Company operates and holds customer funds in both regulated and non-regulated entities.
For the fiscal years ended December 31, 2022 and 2021, approximately $1,646,307 thousand and $1,011,375 thousand, respectively, represented e-money issued, and approximately $220,669 thousand and $259,448 thousand, respectively, represented funds within the transaction settlement cycle. In addition, for the fiscal year ended December 31, 2021, $387,456 thousand of cash was held in escrow related to the draw down of the USD Incremental Term Loan (as defined in the Form 20-F for the fiscal year ended December 31, 2022) which was included within "Customer accounts and other restricted cash, net". This cash was restricted from use until the completion of the SafetyPay acquisition which was completed in the first quarter of 2022 as disclosed in the Form 20-F for the fiscal year ended December 31, 2022.
For regulated entities, the amounts included in "Customer accounts and other restricted cash, net" reflect those required to be segregated in safeguarded bank accounts, pursuant to the rules of the UK Financial Conduct Authority and Central Bank of Ireland in order to cover the liabilities classified as “funds payable and amounts due to customers.” These funds represent both e-money and funds held on behalf of customers/merchants prior to settlement. The safeguarded bank accounts are in Paysafe’s name and Paysafe has the ability to transfer and direct the use of the funds. However, if Paysafe were to spend these funds, it would need to obtain a letter of credit or transfer its own funds into these safeguarded accounts due to the above-mentioned regulations. The excess funds held on behalf of customers and merchants, beyond what is required to be segregated/safeguarded, are transferred to “Cash and cash equivalents” at the end of each reporting period. The total amount of "Customer accounts and other restricted cash, net" held within regulated entities is present in both the Merchant Solutions and Digital Wallet segments, with a majority in Digital Wallets.
For non-regulated entities, a majority of the amounts included in "Customer accounts and other restricted cash, net" reflect those held on behalf of customers/merchants prior to settlement. The funds are held in separate bank accounts in Paysafe’s name, and so Paysafe is able direct the use of the funds. However, in practice, it is unlikely Paysafe would spend these funds on operations as they are needed to settle liabilities to customers and merchants as they become due. The total amount of "Customer accounts and other restricted cash, net" held within non-regulated entities is present in the Digital Wallets segment.
In accordance with ASC 230-10-50-7, ASC 230-10-45-4, and Rule 5-01(1) of Regulation S-X, and in consideration of the definition of restricted cash per BC9 of ASU 2016-18, the Company will revise the customer accounts and other restricted cash, net disclosure in Note 1 to the audited
financials consolidated financial statements of the Form 20-F for the fiscal year ended December 31, 2023 to provide greater detail regarding the nature and types of amounts included in this account. The revised disclosure to be prospectively included in Note 1 is as follows:
i.Note 1: Customer accounts and other restricted cash, net
Under As part of the Company’s regulatory requirements settlement cycle, the Company is required to safeguard receives customer funds that have been received either in exchange for electronic money (“e-money”) issued or within the transaction settlement cycle to merchants. Such amounts are recorded in Customer accounts and other restricted cash in our Consolidated Statements of Financial Position, as described below. The Company operates and holds this type of customer fund in both regulated and non- regulated entities.
For regulated entities, the Company is required to comply with certain safeguarding requirements of customer funds. Depending on the underlying regulations, the Company may satisfy these safeguarding requirements either by placing qualifying liquid assets cash or cash equivalents in a segregated bank account, by ensuring the funds are with an authorized insurer or by obtaining guarantees from an authorized credit institution. The cash and cash equivalents held in a segregated bank account to meet these safeguarding requirements are included in “customer accounts and other restricted cash, net” and represent a majority of the balance. For non-regulated entities, all customer funds held in a segregated bank account are included within “customer accounts and other restricted cash, net.”
Customer accounts and other restricted cash, net include cash on hand and liquid investments cash equivalents with a maturity of thre
Show Raw Text
CORRESP
1
filename1.htm
CORRESP
January 15, 2024
Blaise Rhodes
Rufus Decker
Division of Corporate Finance
Office of Trade & Services
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Paysafe Limited
Form 20-F for the Fiscal Year Ended December 31, 2022
Form 6-K filed November 14, 2023
File No. 001-40302
Dear Ms. Rhodes and Mr. Decker:
On behalf of Paysafe Limited (the “Company,” “Paysafe,” “we,” or “us”), we hereby submit this letter in response to comments contained in the letter of the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission dated December 7, 2023 (the “Comment Letter”) related to the Company’s Form 20-F for the fiscal year ended December 31, 2022 and the Form 6-K filed November 14, 2023. For the convenience of the Staff, for each of the Staff’s comments, we have repeated the text of the comment below in bold text and followed the comment with the Company’s response. Attached as Exhibit A to this letter is a copy of the earnings release dated November 14, 2023, marked to show the approach we intend to take in our future earnings releases in response to the comments in the Comment Letter. Additions are shown in underline and deletions are marked as strikethrough.
Form 20-F for the Fiscal Year Ended December 31, 2022
Financial Statements
Consolidated Statements of Comprehensive Loss, page F-5
1.Please disclose the earnings per share information for each period presented on the face of your statements of comprehensive loss. Refer to ASC 260-10-45-2.
Basic and diluted earnings per share for the periods ended December 31, 2022, 2021 and 2020 were ($30.78), ($1.84) and ($2.10), respectively. The Company acknowledges that these amounts were included in Note 3 of the financial statements in the prior years rather than the face of the financial statements.
Paysafe began including earnings per share information in its interim unaudited consolidated statements of comprehensive loss, starting with the interim period ended March 31, 2023 filed on Form 6-K on May 16, 2023, in order to comply with ASC 260-10-45-2. The Form 20-F for the fiscal year ended December 31, 2023, the earnings release for the quarter ending December 31,
2023 to be furnished on Form 6-K and future filings will also include earnings per share information for each period on the face of the consolidated statement of comprehensive loss.
Consolidated Statements of Cash Flows, page F-10
2.Please tell us and disclose whether funds payable and amounts due to customers are amounts that must be refunded to the customer or remitted to a third party. Also, tell us how you determined an increase in funds payable and amounts due to customers is an operating cash inflow, rather than a financing cash inflow that is more akin to a borrowing. In addition, tell us how you determined a decrease in funds payable and amounts due to customers is an operating cash outflow, rather than a financing cash outflow. Refer to ASCs 230-10-45-16(a), 230-10-45-17(f), 230-10-45-14(b) and 230-10- 45-15(b).
Mainly within our Digital Wallets segment, the funds from the customer to the merchant flow through Paysafe. We refer to this as “in the flow of funds” as Paysafe holds these funds in our own bank accounts on behalf of the customer, until they are due to a merchant. The liability is to the customer for funds held on behalf of the customer (i.e., wallet/voucher balances) prior to being used. The wallet/voucher balances can be used with a merchant at any time by the customer holding the wallet or voucher. If the customer holds a wallet, these funds can also be withdrawn at any time. A liability becomes due to the merchant when the customer uses the wallet or voucher to make a purchase from the merchant. In the remainder of our Digital Wallets segment, and when we are in the flow of funds within our Merchant Solutions segment, this represents funds owed to the merchants for transactions processed by Paysafe. The Company will revise the funds payable and amounts due to customers disclosure in Note 1 of the FY 2023 Form 20-F to provide greater detail regarding the nature and types of amounts included in this account. The revised disclosure to be prospectively included in Note 1 is as follows:
i.Note 1: Funds Payable and Amounts Due to Customers
When electronic money (“e-money”) is issued, the Company recognizes a liability upon the issuance of e-money to its customers and merchants to the customer equal to the amount of electronic e-money that has been issued. The liability is due to the customer prior to the funds being used.
In addition, where the Company is in the flow of funds in the transaction settlement cycle, a liability is recognized for the amount to be settled to merchants owed to the merchants. A majority of these transactions are net settled, whereby the amounts due to merchants are settled net of the revenue transaction fees owed by the merchant.
These liabilities are presented as “Funds payable and amounts due to customers” in the Company’s Consolidated Statements of Financial Position.
Within our core Digital Wallets business (Digital Wallets segment), when the customer deposits e-money into its wallet, Paysafe records a liability for the “Funds payable and amounts due to customers” and the funds are recorded as “Customer accounts and other restricted cash, net” (or “Settlement receivables, net” for funds in transit). As a licensed e-money issuer Paysafe has the obligation to store, safeguard and process transactions on behalf of its clients. When the customer initiates a transaction (i.e. deposits funds using a payment service provider, makes a purchase from a merchant, etc.), Paysafe recognizes revenue related to digital wallet services and cost of services
2
to the payment service provider that processed the transaction. When we settle with the payment service provider, we settle net of the fees owed which is recorded against “Settlement receivables, net.”
Within our eCash business (Digital Wallets segment), when the customer purchases a voucher, Paysafe records a liability for “Funds payable and amounts due to the customer” and a cost of sale to the distributor that processed the transaction on behalf of Paysafe. For the majority of transactions, the funds we receive from the distributors are net of these costs. Before receipt, these funds are recorded as “Settlement receivables, net,” and following receipt, these funds are reclassified to “Customer accounts and other restricted cash, net.” When the customer uses its voucher with a merchant, Paysafe recognizes revenue from the merchant for providing digital wallet services related to that transaction and funds payable becomes due to the merchant. When we settle with the merchant, we settle net of this revenue for the majority of the transactions.
Within our Merchant Solutions segment, when we are in the flow of funds in the transaction settlement cycle, a liability for “Funds payable and amounts due to customers” is recognized for the amount to be settled to merchants, net of revenue recognized for the payment processing services provided. Concurrently, “Settlement receivables, net” and cost of services is recorded. The funds flow through the Company and to the merchant after the transaction has occurred which is recorded in “Customer accounts and other restricted cash, net”. A majority of these transactions are net settled, whereby the amounts due to merchants are settled net of the revenue transaction fees owed by the merchant.
Based on the above net settlement process, settlement receivables and funds payable and amounts due to customers are similar to trade receivables and trade payables which are considered working capital movements as the balances are directly related to revenue and cost of sales and the cash flow movements are directly related to our operations.
In determining that the change in funds payable and amounts due to customers is an operating cash flow, rather than a financing cash flow, we considered the definitions of “financing activities” and “operating activities” in ASC 230-10-20, the examples of cash inflows from financing activities in ASC 230-10-45-14 and cash outflows for financing activities in ASC 230-10-45-15, and the examples of cash inflows from operating activities in ASC 230-10-45-16 and cash outflows for operating activities in ASC 230-10-45-17. As described in further detail above, these cash flows directly stem from activities that relate to providing services and the cash effects of transactions that enter into the determination of net income. We view the collection of the cash from the customer, and remittance to the customer or merchant to be part of the cash flow directly related to providing our digital wallet and payment processing services and generating revenue in accordance with ASC 230-10-45-16. As such, we believe the presentation within operating for the “funds payable to a customer” is appropriate as the Company views the collection and remittance of funds to be an integral part of providing its service offering.
While the Company believes its policy of presenting the funds payable activity within operating is appropriate and acceptable, the Company also acknowledges that another acceptable presentation alternative could be to present such activity within financing activities. The technical argument supporting financing is to view the collection of funds from the customer as akin to a borrowing, consistent with ASC 230-10-45-14.b. Likewise, the settlement of the funds payable to a customer could be viewed as a “repayment of amounts borrowed” in accordance with ASC 230-10-45-15.b.
Notwithstanding the alternative view of financing presentation, the Company believes that presentation within operating is also acceptable for the reasons outlined above. We further believe
3
that, in substance, the cash flow associated with funds payable is more akin to an operating activity as the funds are obtained for purposes of earning revenue as opposed to raising capital. As such, we believe continued presentation within operating for future filings is appropriate.
3.Please tell us and disclose in greater detail the nature and types of amounts included in customer accounts and other restricted cash, net. Quantify the different types of amounts. Also, tell us how you determined you have control over the amounts included in customer accounts and other restricted cash, net, including whether you (a) have the ability to direct how and when the funds would be used, (b) have physical possession of the funds and/or (c) hold the funds in a bank account in your name and you can transact in this account at any time. Refer to ASCs 230-10-50-7 and 230-10-45-4, Rule 5-02(1) of Regulation S-X and BC9 in ASU 2016-18.
As part of the settlement cycle, the Company receives customer funds either in exchange for electronic money (“e-money”) issued or within the transaction settlement cycle to merchants. The Company operates and holds customer funds in both regulated and non-regulated entities.
For the fiscal years ended December 31, 2022 and 2021, approximately $1,646,307 thousand and $1,011,375 thousand, respectively, represented e-money issued, and approximately $220,669 thousand and $259,448 thousand, respectively, represented funds within the transaction settlement cycle. In addition, for the fiscal year ended December 31, 2021, $387,456 thousand of cash was held in escrow related to the draw down of the USD Incremental Term Loan (as defined in the Form 20-F for the fiscal year ended December 31, 2022) which was included within "Customer accounts and other restricted cash, net". This cash was restricted from use until the completion of the SafetyPay acquisition which was completed in the first quarter of 2022 as disclosed in the Form 20-F for the fiscal year ended December 31, 2022.
For regulated entities, the amounts included in "Customer accounts and other restricted cash, net" reflect those required to be segregated in safeguarded bank accounts, pursuant to the rules of the UK Financial Conduct Authority and Central Bank of Ireland in order to cover the liabilities classified as “funds payable and amounts due to customers.” These funds represent both e-money and funds held on behalf of customers/merchants prior to settlement. The safeguarded bank accounts are in Paysafe’s name and Paysafe has the ability to transfer and direct the use of the funds. However, if Paysafe were to spend these funds, it would need to obtain a letter of credit or transfer its own funds into these safeguarded accounts due to the above-mentioned regulations. The excess funds held on behalf of customers and merchants, beyond what is required to be segregated/safeguarded, are transferred to “Cash and cash equivalents” at the end of each reporting period. The total amount of "Customer accounts and other restricted cash, net" held within regulated entities is present in both the Merchant Solutions and Digital Wallet segments, with a majority in Digital Wallets.
For non-regulated entities, a majority of the amounts included in "Customer accounts and other restricted cash, net" reflect those held on behalf of customers/merchants prior to settlement. The funds are held in separate bank accounts in Paysafe’s name, and so Paysafe is able direct the use of the funds. However, in practice, it is unlikely Paysafe would spend these funds on operations as they are needed to settle liabilities to customers and merchants as they become due. The total amount of "Customer accounts and other restricted cash, net" held within non-regulated entities is present in the Digital Wallets segment.
In accordance with ASC 230-10-50-7, ASC 230-10-45-4, and Rule 5-01(1) of Regulation S-X, and in consideration of the definition of restricted cash per BC9 of ASU 2016-18, the Company will revise the customer accounts and other restricted cash, net disclosure in Note 1 to the audited
4
financials consolidated financial statements of the Form 20-F for the fiscal year ended December 31, 2023 to provide greater detail regarding the nature and types of amounts included in this account. The revised disclosure to be prospectively included in Note 1 is as follows:
i.Note 1: Customer accounts and other restricted cash, net
Under As part of the Company’s regulatory requirements settlement cycle, the Company is required to safeguard receives customer funds that have been received either in exchange for electronic money (“e-money”) issued or within the transaction settlement cycle to merchants. Such amounts are recorded in Customer accounts and other restricted cash in our Consolidated Statements of Financial Position, as described below. The Company operates and holds this type of customer fund in both regulated and non- regulated entities.
For regulated entities, the Company is required to comply with certain safeguarding requirements of customer funds. Depending on the underlying regulations, the Company may satisfy these safeguarding requirements either by placing qualifying liquid assets cash or cash equivalents in a segregated bank account, by ensuring the funds are with an authorized insurer or by obtaining guarantees from an authorized credit institution. The cash and cash equivalents held in a segregated bank account to meet these safeguarding requirements are included in “customer accounts and other restricted cash, net” and represent a majority of the balance. For non-regulated entities, all customer funds held in a segregated bank account are included within “customer accounts and other restricted cash, net.”
Customer accounts and other restricted cash, net include cash on hand and liquid investments cash equivalents with a maturity of thre