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Disclosures

Overview#

As with any program that offers banking products or services to the public, our bank partners require that Unit’s clients provide certain disclosures to end-customers before they apply for a bank account. This is standard industry practice, and we have worked hard with our banks to ensure their requirements are as clear and limited as possible.

Required Disclosures#

The disclosures you need to provide to your customers are as follows:

Consent to Electronic Disclosures: Establishes your ability to provide all disclosures electronically through your platform.

  • It should be shared with your customers first, to capture their consent to receive other disclosures electronically.
  • A customer must consent to this disclosure before you can share other disclosures with them electronically.
  • Unit has provided a template Consent to Electronic Disclosure in your Onboarding Folder.

Deposit Terms & Conditions: These terms govern the use of your deposit product.

  • This agreement is between the bank and your end customer.
  • Unit will provide you with a template for typical deposit accounts.
  • If you plan to pay interest to your customers, we will discuss with you setting up a dynamic disclosure that automatically updates the interest rates you offer in your terms and conditions.

Cardholder Terms and Conditions: These terms govern use related to your card product (if offered).

  • Only for card products
  • These terms are between the bank and your customer.
  • Unit provides a template for debit card products in your Onboarding Folder.

Cash Advance Terms and Conditions: These terms govern the cash advance product offered to your customers (if applicable).

  • Only for cash advance customers
  • These terms are between the bank and your customer.
  • Unit provides a template for cash advance products in your Onboarding Folder.

Client Privacy Policy: General privacy policy governing your privacy practices.

  • This policy applies to all products you offer, whether financial or not.

Client Terms of Service: General terms of service that apply to all products offered on your platform.

  • These terms apply to all products you offer, whether financial or non-financial.
  • This agreement is between you and your customer; it should not include your banking terms and conditions.
  • You will need to capture your customers’ consent to these terms.

Acknowledgement and Retention of Disclosures#

You may link to the the above disclosures on your website, as long as (i) your customers check a box to indicate their acceptance of the them and (ii) you retain the following information for your records:

  • Customer Name.
  • Timestamp of acceptance.
  • Agreement version accepted (e.g. v1.2).
  • Status (whether they agree or not).
  • A record of all versions the customer has consented to.

Sample Acknowledgement Display

Customer Interface Disclosures - Website Footer#

The below disclosures must be displayed on pages of the web or mobile application where you are discussing the financial product, as well as during the account opening process. Most of our clients display these disclosures as a footer on their website or mobile application. The following disclosures are based on the product type you offer. Information in red text should be swapped with your specific information.

Bank Account#

[Client Name] is a financial technology company and is not a bank. Banking services provided by [Bank Name]; Member FDIC.

Bank Account with Debit Card#

[Client Name] is a financial technology company and is not a bank. Banking services provided by [Bank Name]; Member FDIC.  The [Client Name] Visa® Debit Card is issued by [Bank Name] pursuant to a license from Visa U.S.A. Inc. and may be used everywhere Visa debit cards are accepted.

Website Footer#

You should include the following in the footer of your website or in some information section of your application:

  • Your customer service email address;
  • Telephone number;
  • Any other means of connecting with you;
  • Link to the terms and conditions disclosures referenced earlier on this guide.

Fraud SMS Text Alert Disclosure (card products only)#

The following information must be disclosed on your website if you are offering card products. You can disclose this information via an FAQ document or the legal disclosures link you provide at the footer of your website. We provide an example below where the disclosure is included in an FAQ, but only the italicized answer is the required disclosure. Information red should be swapped with your specific information.

Do you offer SMS or text messaging to provide fraud alerts?

Messaging frequency depends on account activity. For more information, text HELP to 23618. To cancel fraud text messaging services at any time reply STOP to any alert from your mobile device.

For fraud alerts support, call [insert number] or email [insert email]. By giving us your mobile number, you agree that fraud alerts text messaging is authorized to notify you of suspected incidents of financial or identity fraud. HELP instructions: Text HELP to 23618 for help or call [insert number] or email [insert email]. Stop instructions: Text STOP to 23618 to cancel.

Release of Liability: Alerts sent via SMS may not be delivered to you if your phone is not in the range of a transmission site, or if sufficient network capacity is not available at a particular time. Even within coverage, factors beyond the control of wireless carriers may interfere with messages delivery for which the carrier is not responsible. Carriers do not guarantee that alerts will be delivered.

Changing End-User Terms & Updating Disclosures#

As you continue to develop and evolve your product offering, you may decide to make changes to your account structure that can affect your end-user’s product experience, such as increasing or decreasing ACH limits, adding or removing certain account or transactional fees or even adding new features or services that may incur additional fees.

In these scenarios, when making changes to your deposit products that will alter the end-user terms and conditions, you may be required to communicate these changes to your customers depending on whether the changes being made to the accounts are adverse or in the customer’s favor.

If you are going to be making changes to your account structure, limits or fee structure post-launch and those changes are in the favor of the end-customer, the requirements from a compliance perspective are as follows:

  • Consult your Unit Customer Success Manager to communicate the changes that you would like to make to your account - please provide all relevant information pertaining to the updates. Some examples of account changes in favor of the end-customer include (among others):
    • Increasing the daily or monthly ACH debit or credit limits on the account
    • Increasing the daily point-of-sale or ATM withdrawal limits
    • Decreasing the fee for a particular service or feature
    • Removing a fee for a particular service or feature
    • The Unit Compliance team will work with legal counsel to update the relevant language as necessary in the impacted agreement as it pertains to the change being made.
  • Provide communication to your customers to notify them of the change, along with a version of the updated terms and conditions.

If you will be making changes to those fees that are adverse to your end-customers, the compliance requirements are as follows:

  • Consult your Unit Customer Success Manager to communicate the changes that you would like to make to your account - please provide all relevant information pertaining to the updates. Some examples of account changes that are adverse to the end-customer include (among others):
    • Decreasing the daily or monthly ACH debit or credit limits on the account
    • Decreasing the daily point-of-sale or ATM withdrawal limits
    • Increasing the fee for a particular service or feature
    • Adding a fee for a particular service or feature
  • Important to Note: For changes being made to the account that are adverse to end customers, you are required by law to notify customers at least 30 days prior to that change taking effect. Because of this requirement, it’s strongly encouraged that you communicate any adverse changes to your account to Unit well in advance of when you plan to have that change take effect.
  • The Unit Compliance team will work with legal counsel to update the relevant language as necessary in the impacted agreement as it pertains to the change being made.