Servizi di marketing basati su Treasury

Many states have statutory prohibitions on references to “banking," “banks," and “bank accounts” when the entities making these references are not state- or federally-chartered banks or credit unions. Imprecise terminology of Financial Accounts for platforms accounts might draw scrutiny from regulators.

Recommended Terms

For your platform to efficiently use Financial Accounts for platforms, you need to brand and communicate the nature of the product while being mindful of regulations. Refer to the following list of recommended terms to use in your messaging when building out your implementation of the product.

• Money management, or money management account or solution
• Cash management, or cash management account or solution
• [Your brand] account
• Servizi finanziari
• Conto finanziario
• Financial product
• Financial service product
• Store of funds
• Wallet or open loop wallet
• Stored-value account
• Open-Loop stored-value account
• Prepaid access account
• Eligible for FDIC “pass-through” insurance
• Funds held at [Partner Bank], Member FDIC

Terms to Avoid

Avoid the terms in this list for any marketing programs you create because only financial institutions licensed as banks can use them.

• Stripe or [Your Brand] bank
• Conto bancario
• Bank balance
• Servizi bancari
• Banking account
• Banking product
• Piattaforma Banking
• Depositi
• Mobile banking
• [Your Brand] pays interest
• [Your Brand] sets interest rates
• [Your Brand] advances funds
• Phrases that suggest your users receive banking products or services directly from bank partners, for example:
  • Create a [Bank Partner] bank account
  • A better way to bank with [Bank Partner]
  • Mobile banking with [Bank Partner]

Cash back compliance marketing guidance

As a platform, you can provide your customers with cash back, calculated in relation to their financial account balance. We understand that this can be a great value proposition as part of your product. When you market and disclose cash back to your potential and existing customers, don’t conflate cash back with yield or interest. We’ve outlined best practices for your marketing disclosures below. If you have any questions on how to present cash back in your marketing, reach out to our compliance team at platform-compliance@stripe.com

• Recommended Terms:
  • Always refer to cash back as “cash back,” “rewards,” or other terms that don’t imply interest.
  • Always disclose prominently in your marketing materials that the cash back program is subject to change and the conditions under which it might change.
  • Notify your existing customers whenever the cash back program has changed. Prominently display the calculation method in their Dashboard.
• Terms to avoid
  • Never refer to cash back as “interest” or “yield.”
  • Don’t reference the Fed Funds Rate as a benchmark for calculating cash back.
  • Don’t imply that cash back is pass-through interest from a bank partner.

How to talk about FDIC pass-through insurance eligibility

Financial Accounts are stored value accounts that are held “for the benefit of” our Financial Accounts for platforms users with our bank partner, Fifth Third Bank, N.A… We disclose to you which of our partners hold your funds. For FDIC pass-through insurance to apply to a user’s balance in a “for the benefit of” account, we must satisfy the rules for FDIC pass-through deposit insurance, unlike a bank account directly with an FDIC insured bank.

We understand that FDIC pass-through insurance eligibility can be a valuable feature to your customers. Stripe has approved the variations of the phrase “FDIC Insurance eligible” noted below on marketing materials, as long as certain conditions are met. Specifically, the statement of FDIC pass-through insurance eligibility must always be paired with two disclosures:

1. Financial Accounts are eligible for FDIC pass-through deposit insurance if they meet certain requirements. The accounts are eligible only to the extent pass-through insurance is permitted by the rules and regulations of the FDIC, and if the requirements for pass-through insurance are satisfied. The FDIC insurance applies up to 250,000 USD per depositor, per financial institution, for deposits held in the same ownership category.
2. You must also disclose that neither Stripe nor you are an FDIC insured institution and that the FDIC’s deposit insurance coverage only protects against the failure of an FDIC insured depository institution.

We have also prepared these FAQs that you can use when your customers have questions about FDIC pass-through insurance eligibility or any of the disclosures: