KES · savings and shares
With the SACCO, under SASRA rules
Pepea Sacco Society Ltd holds member deposits and share capital. Lent only under the by-laws, from Phase 1.
Three places, three sets of rules, none of them a Pepea Technologies account. Every status below says who is reviewing it and since when.
KES · savings and shares
Pepea Sacco Society Ltd holds member deposits and share capital. Lent only under the by-laws, from Phase 1.
KES · wallet float
Money in transit to and from M-Pesa sits in segregated trust accounts under the e-money application.
USD · live
Dollars are held by BacBon in segregated accounts under its licence. Pepea does not custody dollars. Conversion runs at one published spread; nothing in local currency depends on the dollar layer.
| Instrument | Regulator | State |
|---|---|---|
| SACCO registration (non-withdrawable deposit-taking) Pepea Sacco Society Ltd holds member deposits and share capital. | Commissioner for Co-operative Development · SASRA | granted · [ref] · [date] |
| E-money issuer / PSP — Pepea Payments Ltd Money in transit to and from M-Pesa sits in segregated trust accounts. | Central Bank of Kenya | granted · [ref] · [date] |
| Data controller registration Pepea is registered to process members’ personal data. | Office of the Data Protection Commissioner | granted · [ref] · [date] |
| VASP wallet licence — held by BacBon, not Pepea USD is held under BacBon’s CBK VASP wallet licence — Pepea does not hold this licence and does not custody dollars. | Central Bank of Kenya | partner · granted · [ref] · [date] |
Until a statutory Deposit Guarantee Fund covers SACCO members, Pepea holds private deposit cover with [provider] up to KES [limit] per member. The policy document and its exclusions are published here. Share capital is not covered — it is ownership, not a deposit.
A 24-hour hold on the first withdrawal to a new destination above a threshold; device, velocity and SIM-swap checks on every login and transaction; Circle-level rules on sudden order changes and payouts to new numbers. Thresholds are withheld (see the redactions list on /own).
DPIA summary: what we collect (phone, ID for KYC, device, transactions), why, for how long (seven years for ledger records), who processes it (Smile ID, Africa’s Talking, Meta, [sponsor bank]). Every automated decision stores its model version and a plain-language reason.
Security disclosure: [security@pepea.xyz], response within 3 business days.