at present, there are two ways of P2P fund custody, one is to be hosted on a third-party payment platform, and the other is to be deposited in a bank.

firstly, explain the escrow of third-party payment; Then we must understand a very important mode of third-party payment-virtual account mode. Different from the gateway payment mode of third-party payment, in the virtual account mode, both the payee and the payer need to register and open a third-party payment account on the third-party payment platform and associate it with their respective bank accounts. There are two sets of account systems. In the direction of funds, the payer's bank account is transferred to the imprest account opened by the third-party payment company in the bank, and finally the third-party payment company's bank account is transferred to the payee's bank account. In the whole process, the funds pass through the bank account of the third-party payment company.

at present, this model has been clearly denied by the regulatory authorities. In August 216, the four ministries jointly issued the Interim Measures for the Management of Business Activities of Information Intermediaries in peer-to-peer lending. Article 28 peer-to-peer lending information intermediaries should implement the isolated management of their own funds and the funds of lenders and borrowers, and select qualified banking financial institutions as the depository institutions for the funds of lenders and borrowers. Therefore, the P2P hosting business of third-party payment companies has made it clear that it is not allowed.

Previously, the P2P depository mode of the third-party payment company was that investors and borrowers opened accounts in the system of the third-party payment platform respectively, and when the transaction occurred, the funds were directly transferred from the investor's account to the borrower's account, without going through the platform layer, so that the amount of the user's account can be withdrawn and used in real time. However, the funds managed in this mode are actually still placed in the payment reserve account of the payment company, and they are not really dedicated to the special fund account.

According to the latest regulatory documents, the Notice on Doing a Good Job in the Rectification and Acceptance of P2P peer-to-peer lending Risks (No.57) states that the P2P platform can only be operated with bank depository, and gives strict requirements, which makes it clear that the banks engaged in depository business must pass the evaluation of a joint team of China Internet Finance Association, banks and technical service providers. Banks that pass the assessment will be listed in the white list of depository banks of China Internet Finance Association. If they fail or do not apply for the assessment, they will not be able to conduct bank depository business. If the depository banks connected to the P2P platform do not enter the white list, the platform will not be able to pass the filing in June next year.

at present, there are three modes of bank depository cooperation between banks and mutual fund platforms, namely, direct bank depository, direct depository and joint depository. Direct depository and bank direct connection are more compliant depository modes. The reason why joint depository is listed in the red line of national supervision is that user funds do not reach the bank directly, but need to be paid by a third party before they can reach the bank, and the user funds and their flow direction are not supervised by the bank.