When a counterparty asks for “proof of funds,” they usually want one thing: a credible signal that a real bank relationship exists and that the party claiming capacity is not inventing the story. Two formats show up repeatedly: an MT799 narrative sent bank-to-bank, and a bank comfort letter (often called a bank reference letter).
If you are relying on a third party to present non-committal proof of funds on your behalf, the constraints tighten. Banks protect confidentiality. They avoid creating liability. They do not like open-ended reliance by unknown recipients. This article compares the two formats with that reality in mind.
MT799 is a SWIFT FIN free-format narrative message used for bank-to-bank communication. It can convey context, references, and procedural statements. It is not a payment instrument and it is not a commitment to transfer funds unless a bank chooses to assume that liability, which is rare in this context.
A bank comfort letter is typically a letter on bank letterhead (or secure bank channel) that provides limited confirmation, often framed as “for information only.” It may confirm a customer relationship and, in some cases, provide a generic statement about the customer’s standing, subject to strict qualifiers and non-reliance language.
In most real-world situations, a limited bank comfort letter is usually easier to obtain than an MT799 for “proof of funds” purposes, especially when the requested content is non-committal. A comfort letter often fits within standard bank “reference letter” workflows. An MT799 requires a receiving bank’s BIC and a bank-to-bank transmission request, which can trigger additional controls and internal escalation.
| Factor | MT799 | Bank Comfort Letter |
|---|---|---|
| Operational friction | Medium to high. Bank-to-bank routing, recipient validation, internal approvals. | Low to medium. Many banks have standard reference letter templates. |
| Recipient specificity | High. Usually addressed to a specific receiving bank (BIC and references). | Flexible. Can be addressed to a named party or “To Whom It May Concern,” depending on policy. |
| Likelihood of “information only” qualifiers | High. | High. |
| Third-party reliance | Generally limited. Banks tend to restrict reliance to the receiving bank and add non-reliance language. | Generally limited. Many letters include explicit non-reliance and liability limitations. |
| Perceived credibility to counterparties | High when sent directly bank-to-bank, because it confirms a real bank channel was used. | Variable. Credibility depends on verification method and whether the recipient can validate authenticity. |
If you are relying on a third party to present non-committal proof of funds on your behalf, your biggest obstacle is not the format. It is authorization and liability. Most banks will not discuss a client relationship or any account-related fact with an unknown party without explicit client consent. Even with consent, banks keep the language narrow.
If the goal is non-committal comfort, aim for statements that are true, limited, and defensible. Banks will usually tolerate relationship and process statements, paired with clear disclaimers. They avoid language that reads like an undertaking.
| Verbiage Category | Comfort Letter Style | MT799 Style |
|---|---|---|
| Information Only | “This letter is provided for information purposes only and creates no obligation.” | “This message is for information only and does not constitute an undertaking.” |
| Relationship | “We maintain a banking relationship with [Client], subject to confidentiality.” | “We confirm [Client] is known to us, subject to policy and client authorization.” |
| Process Status | “We are reviewing a request, subject to KYC and internal approvals.” | “Any action remains subject to due diligence, KYC and approvals.” |
| Non-Reliance | “No third party may rely on this letter for credit or delivery decisions.” | “No third party reliance. Recipient bank only.” |
For most “soft comfort” scenarios, this is the path with the least friction. It is also the format most commonly watered down into something banks will actually sign.
MT799 can carry more credibility when the recipient values bank channel confirmation. The trade-off is higher operational friction and tighter bank policy constraints.
| Input | What To Provide To The Bank |
|---|---|
| Purpose | One sentence. Keep it narrow. “Counterparty onboarding comfort” is better than “proof of funds to close.” |
| Recipient | Name and address for a comfort letter, or receiving bank name and BIC for an MT799. |
| Authorization | Written client consent that permits disclosure of the minimum necessary facts. |
| Acceptable wording | Explicitly accept “information only,” “subject to approvals,” and “non-reliance” language. |
| Facts only | Do not ask for “blocked funds” or “unencumbered” claims unless you have a real documented control structure. |
No. If the counterparty needs an undertaking, use an instrument that is designed to be an undertaking, with defined presentation conditions and bank liability. Comfort letters and MT799 messages are usually framed as information only.
Banks generally issue reference letters to their own customers, with customer authorization, and they control the wording. If the third party is not the customer, expect confidentiality limits and a narrow scope.
A narrow request, a named recipient, clear consent, and language that does not create a payment obligation. If you try to turn comfort into a guarantee, most banks will refuse or strip the content.
If your counterparty is requesting a non-committal proof of funds, share the exact wording they asked for, who must receive it, and what decision it is meant to support. We will revert with a precise, bank-aligned approach and the most executable path through regulated counterparties.
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