This policy sets forth Unifimoney’s procedures for addressing (i) provisional funding reversals, including non-sufficient funds (NSF) returns after investment execution, and (ii) failed electronic delivery of required account statements resulting in paper statement fees assessed by the clearing broker.
The objectives of this policy are to protect customer and firm assets, mitigate settlement and operational risk, align with standard broker-dealer and clearing firm practices (including those of Apex Clearing), and ensure consistent, transparent, and compliant recovery processes.
This policy applies to all Unifimoney brokerage and investment accounts cleared through Apex Clearing or other custodial partners where:
- Provisional credit is extended and later reversed due to NSF or similar ACH return codes; and/or
- Required statements cannot be delivered electronically, resulting in paper statement delivery.
This includes self-directed brokerage accounts, robo-advisory portfolios, digital asset investments, and precious metals accounts.
All incoming ACH and electronic fund transfers are treated as provisional until final settlement. If a transfer is returned after securities or other assets have been purchased, the account may reflect a debit balance.
Electronic delivery of required statements is the default method. Failure of electronic delivery may result in paper statement delivery and associated fees charged by the clearing broker.
This policy is triggered upon any of the following:
- Receipt of an NSF or ACH return after investment execution;
- Failed electronic statement delivery;
- Assessment of paper statement fees by the clearing broker.
Upon notice of an NSF return, Unifimoney may immediately restrict the account, including suspension of purchases, withdrawals, transfers, and scheduled deposits.
Upon failed statement delivery, Unifimoney will notify the customer and request confirmation or correction of delivery information.
6.1 Cash Offset
Any available cash balance in the investment account will be applied first to offset the negative balance.
6.2 Asset Liquidation Authority
Debit balances may be satisfied through available cash, new deposits, proceeds from customer-initiated transactions, or liquidation of securities or other assets.
Unifimoney and/or the clearing broker are authorized to liquidate assets without prior notice to satisfy debit balances, consistent with clearing broker agreements. Liquidations occur at prevailing market prices, and market risk, spreads, and transaction costs are borne by the customer.
If available cash is insufficient, Unifimoney (or its custodian) is authorized to liquidate investments to cover the negative balance.
Key principles:
- Liquidations may occur without prior notice to the customer
- Liquidations will be executed at prevailing market prices
- Market timing, price fluctuations, spreads, and fees are borne by the customer
- Liquidation decisions are made solely to remedy the funding failure, not as investment advice
This authority aligns with Apex Clearing’s standard negative balance and margin‑like recovery practices.
6.3 Asset‑Specific Handling
- Robo‑advisory portfolios: Assets may be liquidated on a pro‑rata basis consistent with portfolio construction.
- Self‑directed brokerage accounts: Securities may be liquidated at Unifimoney’s or the custodian’s discretion.
- Crypto assets: Positions may be sold subject to market liquidity and exchange conditions.
- Precious metals: Holdings may be liquidated or adjusted in accordance with custody partner rules.
Unifimoney may advance up to two (2) paper statement fees, not to exceed $10 in total, as a customer accommodation.
Any fees advanced will be recorded as a debit balance on the customer’s ledger and treated as a recoverable receivable. This balance is non-interest bearing and does not constitute a penalty.
Customers may be notified electronically of NSF events, failed deliveries, account restrictions, debit balances, and potential liquidation. Notification does not delay recovery actions.Unifimoney generally applies recovery first to available cash and deposits before initiating asset liquidation, where practicable.
Where permitted by law and applicable agreements, Unifimoney reserves the right to:
- Offset debit balances using available funds across linked accounts
- Pursue additional recovery actions if balances remain unresolved
All actions under this policy are administrative in nature and not investment advice. Events and communications will be retained in accordance with SEC and clearing broker recordkeeping requirements.
