[INDIA] RBI, SEBI and IRDAI · Source-code escrow and continuity obligations for critical applications[EU DORA] ICT third-party risk testing required · In force Jan 2025[PRA] SS2/21 UK · Vendor recovery evidence required[MAS] Singapore TRM · Independent vendor recoverability expected[APRA] CPS 230 Australia · Third-party continuity obligations in force[FFIEC] United States · Source-code access and software escrow addressed in third-party contracts[ENTERPRISE] Mission-critical software procurement increasingly requires continuity evidence before contract
[INDIA] RBI, SEBI and IRDAI · Source-code escrow and continuity obligations for critical applications[EU DORA] ICT third-party risk testing required · In force Jan 2025[PRA] SS2/21 UK · Vendor recovery evidence required[MAS] Singapore TRM · Independent vendor recoverability expected[APRA] CPS 230 Australia · Third-party continuity obligations in force[FFIEC] United States · Source-code access and software escrow addressed in third-party contracts[ENTERPRISE] Mission-critical software procurement increasingly requires continuity evidence before contract

Escrow Banking

Automated Trust and Retention Account (TRA) Escrow Platform for Transparent Fund Management

Castler’s TRA escrow solution helps lenders, infrastructure developers, and project owners manage funds with automation, transparency, and regulatory control. It allows for purpose-based fund allocation, milestone-linked disbursements, and real-time visibility for stakeholders. This ensures compliance, speeds up execution, and lowers financial risk in infrastructure and EPC projects.

Purpose-bound fundsMulti-bank visibilityRule-based settlements

Neutral control

Funds remain governed by agreed release conditions

Bank-connected

Escrow operations stay visible across the banking workflow

Audit-ready

Every movement retains a clear operational trail

THE USE CASE

A controlled escrow operating model

Castler’s TRA escrow automates cash flows with compliance, transparency, and timely disbursals across real estate and infrastructure.

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What is Trust & Retention Account (TRA)?

Trust & Retention account is a combination of multiple accounts or an ecosystem of account which is used to manage the cashflows of an organization which is building/managing a high-value infrastructure project. These infrastructure projects can be Solar power plants, large construction sites, Hydro power plants etc. These projects are usually budgeted at high values. Trust & retention accounts seek to protect the project lenders against the credit risk (the risk of debt service default) by insulating the cash flows of the project company.

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Waterfall Model Mechanism in India

The waterfall payment mechanism ensures structured and sequential fund allocation, prioritizing payments based on predefined rules. Widely used in Trust and Retention Accounts (TRA) in India, it streamlines cashflow management for infrastructure projects and debt repayments. Payments are automated based on priorities like taxes, dues, and high-interest debts, enhancing compliance, transparency, and risk mitigation while ensuring budget adherence and operational efficiency.

Project Lender/Sponsor/Financer

These are regulated entities which can be banks, NBFCs, Project finance organizations which are providing finance for such infrastructure related projects.

Borrower/Project Company

This is the entity/organization which is basically the borrower which has taken the credit from project lender to develop the infrastructure projects.

TRA Agent/ Lender’s agent

All the cashflows required to develop/manage this project will be executed from the hands of borrowers by TRA agents. These agents are mandated by Project Lenders

Special Project Vehicle

All these infrastructure projects are executed through a separate company which is created for a special purpose by Project company. Shares of this SPV is held by the sponsors/Lenders of the project.

All the transactions initiated are approved by the Secured trustee, which can be an individual members from the Trusteeship company.

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Here's why Waterfall Mechanism is a game-changer for TRA (Trust and Retention Account)

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The Regulatory Mandate: Core of a TRA Escrow

RERA guidelines for Escrow Account

A Trust Retention Account (TRA) Escrow is not optional. It is a contractually required safeguard for high-stakes finance. Its operation follows a strict agreement that ensures:

Ring-Fenced Revenue : Critical cash flows are legally separated.

Sequential Payments : A set order prioritizes debt service & necessary costs.

Enforced Control : The escrow agent independently manages the terms.

This mandate changes the escrow from a simple account into a strong, enforceable financial control system. It provides lenders with security and gives borrowers a responsible framework.

Secure your transaction on this foundation of trust.

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Key Challenges in Managing Trust and Retention Accounts

Increased Turn Around Time

Project Companies (SPVs) currently manage all their payments/cashflows with TRA agents in an offline mode which basically increases the TAT required to complete the Payment.

No Real time Payment Tracking

Project companies don’t have visibility on which payments are processed and which of them are still yet to be processed on a real time basis.

Manual reminders for Recurring Payments

If there is a recurring payment, then Project companies need to remind the TRA agent as per frequency of payment release

Project companies need to chase Trust agent to release their payments on time which sometime delays the payment.

Manual Payments Between Subaccounts and External Parties

TRA Agents work in an offline setup where they make payments between multiple TRA subaccounts for a borrower and payments to outside parties of the borrower. Multiple payments can make a manual error for payments.

Complex Prioritization and Budget Management

To define the Prioritization of payments based on Amount & Usecase and maintain Budget of Heads of payment, TRA agent need to keep track of all these in an offline manner to manage the cashflow for an infra project.

Manual Management of Standing Instructions

All standing instructions need to be kept in an offline manner to make the respective payment for a project company.

No Unified Cashflow View Across Borrowers

Project lenders don’t have a single view where they can view all the project companies/Borrowers cashflow.

Fragmented Platforms for Payment Processing

TRA agents handle diverse payments like taxes, salaries, and operations, requiring multiple platforms. There's no unified solution to manage or record all transactions.

Lack of Automated Reconciliation Reports

TRA agent don’t have reconciliation report on a merchant level for financial recon activity which is used by Project companies & Lenders.

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Castler’s Escrow Solution for Trust and Retention Account (TRA)

Castler provides an end-to-end Solution to add, manage TRA accounts for enterprises. Some of our features are

Castler provides an end-to-end Solution to add, manage TRA accounts for enterprises. Some of our features are :

Unified account view for all your Master & sub TRA Accounts

Standing Instructions

Waterfall Payment/ Prioritization payment framework

Configurable Budget on Accounts

Customized Payment frequency

Retention amount configuration

Balance Breach & reminder system configuration

ESCROW BANKING

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ESCROW BANKING

Put every release condition and settlement rule in one controlled flow

Bring your escrow structure to Castler for a focused implementation briefing

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