
Investment App Order, Custody and Cash Treatment Checklist
An investment app is an access layer. It may combine advice, execution, custody, fractional holdings, cash and multiple product types, so the app’s branding does not determine whether a transaction is suitable or Shariah compliant.
Educational information only: This is not investment, legal, tax, cybersecurity or Shariah advice. Verify the platform, contract and each underlying asset.
1. Identify the legal provider
Record the contracting entity, platform owner, adviser, broker and custodian. Check applicable FSCA records.
2. Define the service
Establish whether the app offers advice, discretionary management, execution only, research or administration. Record who makes each investment decision.
3. Review the account contract
Capture ownership, nominee, custody, insolvency and termination terms. Distinguish the app interface from the legal account.
4. Identify available instruments
List shares, ETFs, funds, fractional interests, derivatives, crypto assets and cash products separately. They do not share one legal or Shariah character.
5. Examine order handling
Record market, limit, recurring and fractional order rules. Confirm execution venue, price formation and cancellation rights.
6. Verify settlement
Document trade and settlement dates, when ownership is credited and what happens after a failed trade.
7. Review custody evidence
Identify custodian or nominee, account statements and asset-reconciliation process. Ask how clients prove holdings if the app is unavailable.
8. Check fractional ownership
Read the terms for fractions: legal owner, voting, dividends, transfers and sale. Refer unclear contractual exposure for legal and Shariah review.
9. Examine cash treatment
Identify the bank or fund holding uninvested cash, any return earned and how fees or impermissible amounts are handled.
10. Review leverage and lending
Check margin, overdraft, securities lending, short selling and derivatives. Do not assume these are disabled because the app offers halal funds.
11. Reconcile fees
List dealing, spread, platform, custody, foreign-exchange, fund and advice charges. Compare statements with disclosed pricing.
12. Collect asset-level Shariah evidence
Record the methodology, screening date, reviewer and purification data for each selected investment. An app filter is research evidence, not an autonomous Shariah authority.
13. Prepare tax records
Export transactions, costs, distributions and fees for a registered tax practitioner. Preserve records before closing an account.
14. Review security and continuity
Enable appropriate security, maintain recovery contacts and record the provider’s fraud process. Do not store credentials in an estate checklist.
15. Maintain the platform register
Provider, service and licence
Account, ownership and custody
Order, settlement and cash treatment
Fees, tax and security
Asset-level Shariah evidence
Useful official starting points include FSCA regulated-entity information, SARS individual guidance and the Financial Intelligence Centre.
The completed register should show who provides the service, how each order becomes an owned asset and what happens to cash, custody and records outside the screen.
