Custody Process

Getting Started

The custody process for alternative assets begins with submitting the asset for pre-custody review. Once we determine that we can custody the asset, you can open and fund your Millennium Trust custody account and begin investing. For full details, begin exploring the custody process below.

What is the custody process?

Whether you already know which type of asset you are going to invest or just exploring your options, the information below provides all the details on the custody process for each asset class.

Private Equity / Debt

How to start investing
Step 1: Submit Pre-Custody Docs

In order for Millennium Trust to custody an Alternative Investment, we must first perform a Pre-Custody Process to determine that the investment is administratively feasible for Millennium Trust and to ensure proper custody. Millennium does not evaluate or perform due diligence on any investment or investment sponsor for third parties.

Step 2: Open and fund an account

Open An Account

All new accounts must go through a 7-day revocation period before an investment can be made. If you have an existing account with Millennium Trust and you want to custody the asset in the same account, proceed to step 3.

You can open an account by completing our online account application. Contact us if a paper version is needed.

  • For transfers-in-kind, you must submit a copy of your most recent statement from the current custodian reflecting the asset.
  • For rollovers-in-kind, you must submit Millennium's 60-Day Asset Rollover Request along with stated required documentation.
Step 3: Submit Investment Docs

In order for Millennium Trust to process a transaction for an account, specific documentation is required.

Documents required for the private equity/debt assets vary by investment type. Download the Custody Checklists to view the list of required Millennium Trust forms and additional documents.
Private Equity Custody Checklist Private Debt Custody Checklist

You can save valuable time and resources by using the new online Private Placement (PP) Purchase Direction. This secure portal provides a centralized location for you to complete the form and upload the required documentation to process this investment.
Access Online PP Purchase Direction

The online Private Placement Purchase Direction is not available for entities and 401(k) plans, please download the paper version of this form. Once you have completed and signed Millennium Trust’s purchase direction form, gather any additional documentation and send to us for processing.
Download PP Purchase Direction

For Private Debt assets only:
Download Prom Note Servicing Agrmt  Download Mrtg/Deed of Trust Servicing Agrmt

How long will it take?

Private Placement Investing Timeline

Private Placement Investing Timeline

Sponsor: Submit Pre-Custody Docs 2-5 Business Days

Complete MTC's Private Placement Certification form and submit to MTC along with copies of the Offering Memorandum and Subscription Agreement for MTC's Pre-Custody Process.
 

Note: Draft copies of offering memorandums will not be accepted.

Investor: Account Setup 1-2 Business Days
  • Complete a Millennium Adoption Agreement and Transfer or Rollover form.
  • Sign where indicated.
  • Include a copy of a recent statement from your current custodian or retirement plan.
  • Submit to MTC for processing.
Investor: Account Funding 2-4 Weeks
  • Transfer: Custodian-to-custodian transfer can take 2-4 weeks.
  • Rollover from a previous employer's plan can take 5-10 business days.
  • Annual contribution may be made by personal check.

Note:

  • Clearing time on checks is 5 business days from deposit.
  • Investments requested during 7-day revocation period must have additional client approval.
Investor: Making the Investment 2-3 Business Days
  • Review the Investment Documents, complete the Subscription Agreement and MTC's Private Placement Purchase Direction.
  • Submit all documents to MTC for processing.
  • Upon receipt of documents in good order and once funds are cleared and available, investment will be placed within 1 business day.
  • Hedge Funds

    Hedge Funds

    How to start investing
    Step 1: Submit Pre-Custody Docs

    In order for Millennium Trust to custody an Alternative Investment, we must first perform a Pre-Custody Process to determine that the investment is administratively feasible for Millennium Trust and to ensure proper custody. Millennium does not evaluate or perform due diligence on any investment or investment sponsor for third parties.

    Step 2: Open and fund an account

    Open An Account

    All new accounts must go through a 7-day revocation period before an investment can be made. If you have an existing account with Millennium Trust and you want to custody the asset in the same account, proceed to step 3.

    You can open an account by completing our online account application. Contact us if a paper version is needed.

    • For transfers-in-kind, you must submit a copy of your most recent statement from the current custodian reflecting the asset.
    • For rollovers-in-kind, you must submit Millennium's 60-Day Asset Rollover Request along with stated required documentation.
    Step 3: Submit Investment Docs

    Access Online PP Purchase Direction

    In order for Millennium Trust to process a transaction for an account, specific documentation is required. You can save valuable time and resources by using the new online Private Placement (PP) Purchase Direction. This secure portal provides a centralized location for you to complete the form and upload the required documentation to process this investment.

    The online Private Placement Purchase Direction is not available for entities and 401(k) plans, please download the paper version of this form. Once you have completed and signed Millennium Trust’s purchase direction form, gather any additional documentation and send to us for processing.

    Download PP Purchase Direction

    ✓ Completed and signed Subscription Document
    ✓ Check/Wire instructions signed by client - if funds are not going directly to investment

    How long will this take?

    Hedge Fund Investing Timeline

    Sponsor: Submit Pre-Custody Docs 2-5 Business Days

    Complete MTC's Private Placement Certification form and submit to MTC along with copies of the Offering Memorandum and Subscription Agreement for MTC's Pre-Custody Process.
     

    Note: Draft copies of offering memorandums will not be accepted.

    Investor: Account Setup 1-2 Business Days
    • Complete IRA Adoption Agreement and Transfer or Rollover form.
    • Sign where indicated.
    • Include a copy of a recent statement from your current custodian or retirement plan.
    • Submit to MTC for processing.
    Investor: Account Funding 2-4 Weeks
    • Transfer: Custodian-to-custodian transfer can take 2-4 weeks.
    • Rollover from a previous employer's plan can take 5-10 business days.
    • Annual contribution may be made by personal check.

    Note:

    • Clearing time on checks is 5 business days from deposit.
    • Investments requested during 7-day revocation period must have additional client approval.
    Investor: Making the Investment 2-3 Business Days
    • Review the Investment Documents, complete the Subscription Agreement and MTC's Private Placement Purchase Direction.
    • Submit all documents to MTC for processing.
    • Upon receipt of documents in good order and once funds are cleared and available, investment will be placed within 1 business day.
  • Private Equity / Debt

    Private Equity / Debt

    How to start investing
    Step 1: Submit Pre-Custody Docs

    In order for Millennium Trust to custody an Alternative Investment, we must first perform a Pre-Custody Process to determine that the investment is administratively feasible for Millennium Trust and to ensure proper custody. Millennium does not evaluate or perform due diligence on any investment or investment sponsor for third parties.

    Step 2: Open and fund an account

    Open An Account

    All new accounts must go through a 7-day revocation period before an investment can be made. If you have an existing account with Millennium Trust and you want to custody the asset in the same account, proceed to step 3.

    You can open an account by completing our online account application. Contact us if a paper version is needed.

    • For transfers-in-kind, you must submit a copy of your most recent statement from the current custodian reflecting the asset.
    • For rollovers-in-kind, you must submit Millennium's 60-Day Asset Rollover Request along with stated required documentation.
    Step 3: Submit Investment Docs

    In order for Millennium Trust to process a transaction for an account, specific documentation is required.

    Documents required for the private equity/debt assets vary by investment type. Download the Custody Checklists to view the list of required Millennium Trust forms and additional documents.
    Private Equity Custody Checklist Private Debt Custody Checklist

    You can save valuable time and resources by using the new online Private Placement (PP) Purchase Direction. This secure portal provides a centralized location for you to complete the form and upload the required documentation to process this investment.
    Access Online PP Purchase Direction

    The online Private Placement Purchase Direction is not available for entities and 401(k) plans, please download the paper version of this form. Once you have completed and signed Millennium Trust’s purchase direction form, gather any additional documentation and send to us for processing.
    Download PP Purchase Direction

    For Private Debt assets only:
    Download Prom Note Servicing Agrmt  Download Mrtg/Deed of Trust Servicing Agrmt

    How long will it take?

    Private Placement Investing Timeline

    Sponsor: Submit Pre-Custody Docs 2-5 Business Days

    Complete MTC's Private Placement Certification form and submit to MTC along with copies of the Offering Memorandum and Subscription Agreement for MTC's Pre-Custody Process.
     

    Note: Draft copies of offering memorandums will not be accepted.

    Investor: Account Setup 1-2 Business Days
    • Complete a Millennium Adoption Agreement and Transfer or Rollover form.
    • Sign where indicated.
    • Include a copy of a recent statement from your current custodian or retirement plan.
    • Submit to MTC for processing.
    Investor: Account Funding 2-4 Weeks
    • Transfer: Custodian-to-custodian transfer can take 2-4 weeks.
    • Rollover from a previous employer's plan can take 5-10 business days.
    • Annual contribution may be made by personal check.

    Note:

    • Clearing time on checks is 5 business days from deposit.
    • Investments requested during 7-day revocation period must have additional client approval.
    Investor: Making the Investment 2-3 Business Days
    • Review the Investment Documents, complete the Subscription Agreement and MTC's Private Placement Purchase Direction.
    • Submit all documents to MTC for processing.
    • Upon receipt of documents in good order and once funds are cleared and available, investment will be placed within 1 business day.
  • Real Estate / Real Assets

    Real Estate / Real Assets

    How to invest in Real Estate
    Step 1: Open and fund an account

    Open An Account

    All new accounts must go through a 7-day revocation period before an investment can be made. If you have an existing account with Millennium Trust and you want to custody the asset in the same account, proceed to step 2.

    You can open an account by completing our online account application. Contact us if a paper version is needed.

    • For transfers-in-kind, you must submit a copy of your most recent statement from the current custodian reflecting the asset.
    • For rollovers-in-kind, you must submit Millennium's 60-Day Asset Rollover Request along with stated required documentation.

    Note: For Real Estate rollovers-in-kind, list transfer/rollover pre-custody requirements. For deed registration, refer to our Real Estate Investment Direction.

    Download Real Estate Investment Direction

     

    Step 2: Submit an offer to Millennium Trust

    Prior to submitting an offer through our Pre-Custody Process, your Millennium Account must be open for at least 7 days.  The offer must be made in the name of Millennium Trust Co., LLC Custodian FBO (name on the account) (account type). Millennium Trust will be the authorized signer for the contract. Personal funds cannot be used for the deposit or earnest money. All expenses related to the investment must come from your Millennium account.

    The real estate documents below can be emailed to RealEstateAdmin@mtrustcompany.com or faxed to 630-472-5969. This step will take up to 5 business days once paperwork is received in good order unless an Expedited Service fee is paid for 2-day processing.

    Download Real Estate Investment Direction Download Real Property Servicing Agreement

    ✓ Purchase Contract*
    ✓ Real Estate Investment Direction - indicate amount of earnest money to be sent
    ✓ Real Property Servicing Agreement
    ✓ Copy of current tax bill
    ✓ Legal description of property (if not listed on tax bill)*
    ✓ Check/wire instructions for earnest funds

    You will be notified once the pre-custody process has been completed. If the investment is accepted for custody, earnest funds will be released from your Millennium account and the contract will be signed. Once all documents are submitted and found to be acceptable, Millennium will notify you so that you may schedule the closing. When scheduled, notify Millennium of the date. You may then proceed with the steps required for closing.

    * Copies of these documents must be signed by the account holder as “Read & Agreed” on the last page and initialed on all other pages.

    Note: Millennium does not custody real estate located outside of the United States (U.S. territories are acceptable).

    Step 3: Closing Process

    Before closing, the following documents must be submitted to Millennium for review and processing at least 5 days prior to the scheduled closing:

    Download Real Estate Investment Direction

    ✓New Real Estate Investment Direction - indicating the amount of final closing costs
    ✓ Settlement Statement*
    ✓ Commitment for Title*
    ✓ Proposed Deed*
    ✓ Any miscellaneous closing documents*
    ✓ Mortgaged Property - original note and all Lender documents* (if applicable)

    Once all documents are submitted and found to be acceptable, Millennium will execute the closing documents and submit the final closing costs by the day of the closing.

    * Copies of all documents must be signed by the account holder as "Read & Agreed" on the last page and initialed on all other pages.

    Step 4: Ongoing Requirements

    The following items are required and can be ongoing even after the closing is complete on the real estate property:

    ✓ The recorded deed must be sent to Millennium for safekeeping
    ✓ Ongoing expenses and rental income, if applicable, must flow through your Millennium account
    ✓ For Income Producing Properties, a copy of the current Lease or Property Management Agreement must be provided
    ✓ Any changes in current renters or Property Managers must be communicated to Millennium
    ✓ A Comparative Market Analysis (CMA) will be required annually
    ✓ An appraisal will be required for any taxable event, such as a conversion or distribution of the property 

    How long will it take?

    Real Estate Investing Timeline

    Do the Math 1-2 Business Days

    Calculate total cost of ownership. Include property price, taxes, closing costs and ongoing expenses related to the real estate investment.
     

    Note: All expenses must be paid from the Millennium account.

    Account Setup 1-2 Business Days
    • Execute a Millennium Adoption Agreement to open an account.
    • Complete appropriate Transfer or Rollover form to fund the account.
    • Sign where indicated.
    • Include a copy of a recent statement from your current custodian or retirement plan.
    • Submit to Millennium for processing.
    Account Funding 1-4 Weeks
    • Transfer: Custodian-to-custodian transfer can take 2-4 weeks.
    • Rollover from a previous employer's plan can take 5-10 business days.
    • Annual contribution made by personal check or wire require a Deposit Form.

    Note:

    • Clearing time on checks is 5 business days from deposit.
    • Investments requested during 7-day revocation period must have additional client approval.
    Locate Property & Make Offer Days to Months
    • Make offer to Purchase
    • Our Pre-Custody Process must be performed by Millennium to determine that the investment is administratively feasible. Process takes 2-5 business days.
    • Millennium as Custodian, will execute the contract on behalf of account and submit funds to escrow agent.

    Note: Foreign Real Estate is not allowed.

    Non-recourse Loan Processing 30-45 Days
    • Consider the non-recourse lender's requirements and timeline.
    • Review IRS 598, Unrelated Business Taxable Income (UBTI) relating to Unrelated Debt Financed Income (UDFI) with your tax professional.
    Closing 30-45 Days
    • Release of funds will be submitted upon the account being funded, all forms/documents in good order & completion of Millennium's Pre-Custody Process.
    • Recorded Deed is held in custody by Millennium.
    • All ongoing expenses and rental income must flow through the Millennium account.
  • Commodities / Futures

    Commodities / Futures

    Step 1: Select FCM and/or IB

    Download List of FCMs

    Once you select your Futures Commission Merchant (FCM) and/or introducing brokerage firm, you must determine whether or not Millennium has an existing FCM Agreement with them. Click the link below to view a list of FCMs that we currently have agreements with or e-mail FCMSupport@mtrustcompany.com.

    If an FCM Agreement is not in place, the FCM you have selected will need to contact Millennium to process the request.

    Step 2: Complete FCM Docs

    Contact your introducing broker or FCM to obtain the documents required to open a new trading account.

    Step 3: Open and fund an account

    Open An Account

    You can open an account by completing our online account application. Contact us if a paper version is needed.

    For transfers-in-kind you must submit an IRA-to-IRA Account Transfer Authorization or a Qualified Plan Direct Rollover Authorization form with a copy of your most recent statement from the current custodian reflecting the asset (it must be within the last three months).

    How long will this take?

    Futures Investing Timeline

    Broker Initial Setup & IRA Establishment Process 1-2 Business Days Broker
    • Broker supplies client with necessary MTC and FCM documents to open an account trading in futures or foreign currency.
    • Client completes submits documents to FCM.
    • FCM or the broker forwards documents to MTC along with any other applicable documentation.
    • MTC Futures Client Service executes as custodian, FCM account application and documentation, then forwards to FCM.
    • The FCM opens the trading account and faxes/e-mails confirmation to MTC Futures Client Service.

    MTC

    • MTC reviews MTC forms for completeness.
    • MTC establishes the account and notifies the client via a welcome letter.
    • MTC initiates contact with any previous custodian to transfer assets as applicable.

    Note: Investments requested during the seven (7) calendar day IRA revocation period must have additional client approval.

    Transfer/Rollover Follow-up 5 Business Days If funds are not received, MTC follows up:
    • Account Transfers and IRA Rollovers/ Rollovers from Qualified Plans no less than five (5) business days after processing.

    Note: To expedite the transfer process, we encourage you to liquidate assets prior to submitting the Transfer Form or Qualified Plan Direct Rollover Authorization Form and check with your previous custodian to determine if a Medallion Signature Guarantee is required to transfer funds.

    IRA & Futures/Forex Account Funding 1-2 Business Days Funds are received from the transferring custodian and posted to the MTC account.
    • Funds received by wire are available for investment upon receipt.
    • Funds received by check are available for investment five (5) business days from deposit.

    Funds received without identifying paperwork can cause delays.

    • MTC transfers funds to the new trading account according to client’s direction.
    • FCM notifies the broker that funds are available for trading.
  • Marketplace Loans

    Marketplace Loans

    How to start investing
    Step 1: Open and fund an account

    Open An Account

    All new accounts must go through a 7-day revocation period before an investment can be made. If you have an existing account with Millennium Trust and you want to custody the asset in the same account, proceed to step 2.

    You can open an account by completing our online account application. Contact us if a paper version is needed.

    • For transfers-in-kind, you must submit a copy of your most recent statement from the current custodian reflecting the asset.
    • For rollovers-in-kind, you must submit Millennium's 60-Day Asset Rollover Request along with stated required documentation.
    Step 2: Submit Funding Direction

    Access Online MPL Funding Direction

    The Marketplace Lending (MPL) Funding Direction can be used to fund an account on the following platforms:

    ✓ Lending Club
    ✓ LendingRobot
    ✓ Peer Street Funding LLC
    ✓ Prosper Marketplace
    ✓ Streetshares

    If there is a platform that you are interested in funding in that is not listed, please contact us.

    Contact us

    How long will this take?

    Marketplace Lending Timeline

    Investor: Account Setup 1-2 Business Days
    • Complete a Millennium Adoption Agreement and Transfer or Rollover form.
    • Sign where indicated.
    • Include a copy of a recent statement from your current custodian or retirement plan.
    • Submit to MTC for processing.
    Investor: Account Funding 2-4 Weeks
    • Transfer: Custodian-to-custodian transfer can take 2-4 weeks.
    • Rollover from a previous employer's plan can take 5-10 business days.
    • Annual contribution may be made by personal check.

    Note:

    • Clearing time on checks is 5 business days from deposit.
    • Investments requested during 7-day revocation period must have additional client approval.
    Investor: Making the Investment 1-2 Business Days
    • Complete MTC's Marketplace Lending Funding Direction.
    • Submit all documents to MTC for processing.
    • Upon receipt of documents in good order and once funds are cleared and available, investment will be placed within 1 business day.
  • Traditional Assets

    Traditional Assets

    How to start investing
    Step 1: Open and fund an account

    Open An Account

    All new accounts must go through a 7-day revocation period before an investment can be made. If you have an existing account with Millennium Trust and you want to custody the asset in the same account, proceed to step 2.

    You can open an account by completing our online account application. Contact us if a paper version is needed.

    • For transfers-in-kind, you must submit a copy of your most recent statement from the current custodian reflecting the asset.
    • For rollovers-in-kind, you must submit Millennium's 60-Day Asset Rollover Request along with stated required documentation.
    Step 2: Set up online access

    To trade online, you must have access to Millennium Trust Online and have requested trading access. If you do not currently have online or trading access and would like to add it, complete a web access request found in our Forms library.
    Forms Library

    Step 3: Direct Investment

    Millennium Trust offers two ways for account holders to trade Stocks, Mutual Funds, and Exchange Traded Funds (ETFs) – online and by phone.

    • You can trade online during market hours: 8:30 a.m. – 3:00 p.m. CT, Monday through Friday except for stock market holidays.
    • To place a trade via phone, please call 1.800.258.7878, option 7 during normal trading hours.

    Bonds and CDs can only be traded via phone.

How do I ensure my asset can be custodied (Pre-Custody Process)?

Select your account type:

Access Online Pre-Custody Process

Documents required for alternative assets vary by investment type. Download the Custody Checklist to view the list of required Millennium Trust forms and additional documents.

Hedge Funds Custody Checklist

You can save valuable time and resources by using the new online Pre-Custody Process. This secure portal provides a centralized location for an investment sponsor, advisor or individual investor to work collaboratively in submitting the required documents.

Begin the online Pre-Custody Process by submitting basic investment information. If you are an individual investor or advisor, there is an option to send the investment or fund sponsor instructions to complete the online Private Placement Certification (PPC) as part of the Pre-Custody Process.

Once all the information has been completed and we have received all the necessary documentation, it will take up to 5 business days for us to determine whether Millennium is able to custody the asset.

Return to all steps

Access Online Pre-Custody Process

Documents required for the private equity/debt assets vary by investment type. Download the Custody Checklist to view the list of required Millennium Trust forms and additional documents.

Private Equity Custody Checklist Private Debt Custody Checklist

You can save valuable time and resources by using the new online Pre-Custody Process. This secure portal provides a centralized location for an investment sponsor, advisor or individual investor to work collaboratively in submitting the required documents.

Begin the online Pre-Custody Process by submitting basic investment information. If you are an individual investor or advisor, there is an option to send the investment or fund sponsor instructions to complete the online Private Placement Certification (PPC) as part of the Pre-Custody Process. If you are investing in private debt with no investment sponsor, you can download the required documents below and upload your investment documents during your online submission.

Once all the information has been completed and we have received all the necessary documentation, it will take up to 5 business days for us to determine whether Millennium is able to custody the asset.

For Private Debt assets only:
Download Prom Note Servicing Agrmt 
Download Mrtg/Deed of Trust Servicing Agrmt

Return to all steps

Download the Custody Checklist to view the list of required Millennium Trust forms and additional documents.
Real Estate Custody Checklist

The real estate documents below can be faxed to 630-472-5969 or emailed to RealEstateAdmin@mtrustcompany.com. This step will take up to 5 business days once paperwork is received in good order unless an Expedited Service fee is paid for 2-day processing.
Download RE Investment Direction Download Real Prop Servicing Agrmt

✓ Purchase Contract*
✓ RE Investment Direction - indicate amount of earnest money to be sent
✓ Real Property Servicing Agreement
✓ Copy of current tax bill
✓ Legal description of property (if not listed on tax bill)*
✓ Check/wire instructions for earnest funds

You will be notified once the pre-custody process has been completed. If the investment is accepted for custody, earnest funds will be released from your Millennium account and the contract will be signed. Once all documents are submitted and found to be acceptable, Millennium will notify you so that you may schedule the closing. When scheduled, notify Millennium of the date. You may then proceed with the steps required for closing.

* Copies of these documents must be signed by the account holder as “Read & Agreed” on the last page and initialed on all other pages.

Note: Millennium does not custody real estate located outside of the United States (U.S. territories are acceptable).

Return to all steps