Safeguarding of End-User Funds
COBBY PAY LTD. — Retail Payment Activities Act
Effective date: 7 October 2026
This disclosure explains, at a high level, how CobbyPay approaches the protection of end-user funds where CobbyPay holds funds that are subject to safeguarding requirements under Canada’s Retail Payment Activities Act (“RPAA”) and Retail Payment Activities Regulations (“RPAR”).
1. CobbyPay’s status
CobbyPay is registered with the Bank of Canada as a payment service provider under the RPAA. The Bank of Canada supervises registered PSPs for compliance with applicable RPAA requirements, including operational risk management and, where applicable, safeguarding of end-user funds.
2. Safeguarding objective
Where the RPAA safeguarding requirements apply, CobbyPay maintains arrangements and a written safeguarding-of-funds framework designed to support (i) reliable access without delay to end-user funds being held and (ii) protection of those funds against financial loss in the event of CobbyPay’s insolvency, in accordance with applicable law.
3. How arrangements may operate
The exact safeguarding treatment may vary by product, currency, payment rail and underlying provider. CobbyPay may use safeguarding structures permitted by applicable Canadian law and may rely on regulated financial institutions or other authorized service providers as part of the payment and safeguarding architecture. CobbyPay periodically evaluates its safeguarding arrangements and related legal and operational risks as required.
4. Not a bank deposit
CobbyPay is not a bank. A balance shown through CobbyPay is not represented by CobbyPay as a bank deposit with CobbyPay. Safeguarding under the RPAA is distinct from deposit insurance, and CobbyPay does not represent that Client funds are insured by the Canada Deposit Insurance Corporation or another deposit guarantee scheme unless a specific product disclosure expressly states otherwise.
5. Access, reconciliation and operational controls
CobbyPay maintains operational and reconciliation controls intended to identify the amount of end-user funds held and the corresponding safeguarding requirement. Access to funds may nevertheless be affected by lawful compliance holds, sanctions, fraud prevention, court orders, technical incidents, settlement cycles, third-party failures or other circumstances permitted by law.
6. Third parties
Payment and safeguarding arrangements may involve third-party banks, payment institutions, electronic money institutions, processors, correspondents or other service providers. CobbyPay manages material third-party risks within its operational risk framework, but the identity of providers and specific arrangements may change over time.
7. Insolvency and legal treatment
Safeguarding arrangements are designed to meet applicable RPAA requirements concerning insolvency protection. The legal treatment of funds in a particular event may depend on the relevant safeguarding structure, applicable law and the circumstances at that time.
8. Questions
Questions about this disclosure may be sent to info@cobbypay.com.