March 17, 2021

Please contact your account manager for information about feature availability and enabling and testing new features.

1 FundAmerica

1.2 Update limits for crowdfunding

Based on recent SEC changes as of March 15th, 2021, the maximum raise limits for Reg CF, Reg A Tier 2, and Reg D changed:

  • Reg CF (Section 4(a)(6) ) - $1.07 M → $5 M

  • Reg D rule 504 - $5 M → $10 M

  • Reg A Tier 2 - $50 M → $75 M

FundAmerica system limits now allows raises up to the new limits for each of these three types of offerings.

1.3 Update test for income/worth for non-accredited investors

Also based on recent SEC changes as of March 15th, 2021, the test for income/worth for non-accredited investors changes: The greater of $2,200 or five percent of the greater of the investor’s annual income or net worth, if both an investor’s annual income and net worth are less than $107,000; or

Ten percent of the greater of his or her annual income or net worth, if either of annual income or net worth is equal to or more than $107,000.

1.4 Accredited investors qualifying options

Based on the SEC’s updated definition for an accredited investor, this change adds the following additional options to FundAmerica’s set of accredited investor qualifying options:

  • Certified individual: I am an individual with certifications or credentials issued by an accredited educational institution including, but not limited to, order holders in good standing of the FINRA Series 7, Series 65 and Series 82 licenses.

  • Knowledgeable employee: This is a private fund and I am a "knowledgeable employee" of this fund.

  • Spousal pool: I have pooled my finances with my "spousal equivalent" and qualify as an accredited investor.

  • Foreign entity: An entity, including Indian tribes, governmental bodies, funds, and entities organized under the laws of foreign countries, that own “investments,” as defined in Rule 2a51-1(b) under the Investment Company Act, in excess of $5 million and that was not formed for the specific purpose of investing in the securities offered.

  • Family office: A “family office” with at least $5 million in assets under management and their “family clients".

2 Prime Liquidity

2.1 Update error message for lack of disbursable funds

Previously, the system returned the following error message when there isn’t enough disbursable funds:

“cannot be greater than $X. The fee for this trade is $X(2.0%).”

The system now returns a more user-friendly error message:

"Quote amount including fees exceeds disbursable amount".

3 Prime Issuance - BETA

3.1 Ability to specify email templates per Org ID

This feature enables Organizations to customize the email templates that are sent to Cardholders when issuing a card. Backend work integrates our email service provider’s templating system. The templates can be specified in the account policy:

  • cardholder-verification-invite-template

  • cardholder-verification-code-template

4 Prime Rails

4.1 Update wire instruction presentation

This change applies to all Cloud Prime Trust users with Accounts in the system.

4.2 Create Push Transfer Method

This feature enables an API integrator to create a Push Transfer Method for an Account:Contact pair so that money can be deposited to that account by sending an ACH push transfer.

This feature is enabled per Organization and allows one method per Account ID / Contact ID pair. When generating a new Push Transfer Method or retrieving and existing one, the system returns the following values:

  • Account number

  • Bank Details (Routing Number, Name, Address, Phone number)

  • Supported Transfer types: ACH

  • Credit To

Please note that this feature is released but still in beta testing.

4.3 Process inbound ACH Contributions originated outside of Prime Trust

This feature enables our system to create a Contribution and Funds Transfer for accounts with a Push Transfer Method after receiving an ACH payment from our banking partner.

Transactions are available to view in Cloud Prime Trust under Transactions -> External Transfers and Transactions -> Transaction Ledger.

Please note that this feature is released but still in beta testing.


My Prime Trust

April 30th marks the end of and the migration to

The following work has been completed:

  • Statements as generated on are now available on

  • All emails notices with links to my.primetrust will change to

  • Password reset link moved to

  • Login to from website

  • Banner on login page and main banner page of my.primetrust

In progress:

  • Pop up model for acknowledgment of my.primetrust change