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Rewards Guide

General Guidance#

Rewards programs can encompass a wide variety of different kinds of bonuses and rewards, including cash back, referrals, loyalty programs, spend incentive programs, points programs and more (defined as “Rewards Programs” for the remainder of this guide). 

There are a number of requirements to consider when marketing and disclosing any Rewards Program, and the applicable material information necessary to disclose to end-customers regarding how the rewards can be earned or awarded may vary depending on the type of bonus being offered and the regulations that apply.

In addition to the requirements and considerations outlined in the sections below, Unit’s bank partners have required that each award bonus campaign – particularly if they are referral bonus programs – include a “circuit breaker” threshold (for example, following the first 10,000 accounts that have been onboarded after program launch), at which point they will pause the program to review its effectiveness and to ensure that accounts being opened as a result of the program are not fraudulent or engaging in fraudulent activity.

This threshold does need to be communicated to end-customers or included in the program terms and conditions, as the associated terms should include language on the condition that the program can be ended at any time at the client’s sole discretion.

Please note that for referral bonus programs or other one-time incentive rewards, Unit’s bank partners may require that clients hold the total amount of funds necessary to cover all potential reward bonus payouts in a Reserve account to ensure that the funds are available for reward fulfillment.

Examples of rewards#

Unit provides a flexible platform that makes it easy to implement rewards and be creative with what activity you incentivize. You are not limited to creating rewards like the below examples.

Some examples of Unit customers who have implemented rewards are:

  • Provide cash back on card spend (Enzo)
  • Incentivize customer referrals (Mos)
  • Reward for completing tasks (Bridge)

Marketing #

When offering a Rewards Program for your account holders, here are some of the details you’ll want to include in your marketing material: 

  1. Description of what the reward being offered is (i.e., if it’s a cash reward, be specific about the amount being offered)

  2. All eligibility requirements related to earning the reward: 

    • For example, if direct deposits are required in order to obtain the reward, what types of direct deposits qualify? Does it have to be a specific type of deposit like payroll, government benefits, or other external income sources? Can it be monthly annuity or investment disbursements? 
    • Also, if there is a minimum dollar amount required to earn the reward, for example a minimum balance requirement, or a minimum amount that must be deposited, that amount should be clearly and explicitly stated. 
    • Be clear about any restrictions related to earning the reward as well. Using the above example of direct deposits, will receiving the first deposit be enough to earn the reward bonus, or will the customer require at least two consecutive deposits to be made before they are eligible to receive the reward?
    • Are there any caps or limits to the amount of rewards that can be earned by one customer, or a limit to the number of eligible customers that can receive the reward bonus? If so, this information should be clearly disclosed in any marketing materials referencing or advertising the program. (For example, a customer can only earn a maximum of $250 in cashback rewards in a calendar year; or only the first 20,000 eligible customers can receive a referral bonus.)
  3. Clear communication of when the account holder will receive the reward after meeting the eligibility requirements. (i.e. will they receive the points/cash back immediately upon meeting the eligibility requirements, or will the reward be available to them at the end of the month, or at the end of the year?)

Terms & Conditions#

The Terms and Conditions for any Rewards Program should clearly and accurately describe how the program works. Please find below a non-exhaustive guide of items that must be included: 

Eligibility/Enrollment#

Terms for the Rewards Program should include detailed information regarding the eligibility and enrollment requirements, if any, that are applicable for the end customers participating in your program. 

  1. If there are separate requirements for enrolling or if there are certain eligibility requirements that may restrict some account holders from joining the program (for example, a stipulation that the account holder must have an active account for 6+ months before earning cash back), then those restrictions must be detailed within the program terms. 
  2. In addition, if there are any minimum balance requirements or minimum deposit requirements that can restrict an account holder’s participation in the program, that information must be disclosed as well. 
  3. Bank partners will require information pertaining to any caps or limits on the number of eligible customers that can receive a rewards bonus, in the instance of referral bonus programs, or any other incentive bonus structures where the rewards are limited to a finite number of end-customers. (For example, if a client wishes to offer a referral bonus that will award $10 to each customer who refers a new member to the platform if that member deposits a minimum of $100 within their first month after account opening, and this $10 bonus will only be available to the first 20,000 customers who are eligible and meet those criteria, then that cap must be included in the terms and conditions of the program.)

Earning Rewards#

The terms should also disclose, in sufficient detail, the process for earning rewards and how the cash back or points amount is calculated. 

  1. The requirements for earning rewards should be detailed in a clear manner and should include all purchases or transactions that are eligible to earn rewards, as well as any purchases or transactions that will not earn the account holder rewards. 
  2. Terms should also clearly and concisely detail the process for how cash back or points-based rewards are calculated, as well as any extraneous stipulations that may affect an account holder’s rewards accumulation or balance. 
  3. For example, program terms should clearly outline scenarios such as returns or transaction reversals and how these circumstances may impact reward balance. If an account holder returns a purchase after having received rewards for making that purchase, are the rewards earned retracted from their account? Terms should include detailed explanations of these scenarios to limit risk and liability. 

Receiving Reward Redemption#

In addition to how the rewards can be earned by account holders and any stipulated restrictions that may prevent the earning of rewards, program terms must also outline and describe in detail the process of reward fulfillment and when account holders will be receiving the earned rewards in their account.

  1. Cash back or points-based reward fulfillment can vary depending on the program and depending on how the rewards are earned, but can range anywhere from daily reward fulfillment (account holders receive the cash back in their account the same day that they make a qualifying purchase on their debit card) to weekly, monthly or even quarterly or yearly. 
  2. Whenever the fulfillment period is for your Rewards Program, please ensure that the terms clearly outline the process involved in how the rewards are allocated to an user’s account, as well as how the account holder is able to access their rewards and any information related to reward redemption or withdrawal, if applicable. 
  3. Furthermore, if there are any caps or limits to the amount of rewards (cash back, points or otherwise) that an account holder can earn in a certain period of time (for example, if the account holder can only earn up to $1,000 in cash back in a calendar year), those limits or caps should be clearly disclosed in the terms as well.
  4. The terms should also cover whether returns or transaction reversals affect earning and redemption of rewards.

Reward Balance Upon Account Closure#

Program terms for rewards should also cover the process for redemption or withdrawal of earned rewards for account holders who have closed their account, or have accounts that are not active or in good standing. Terms should also disclose what will happen to an account holder’s accrued but unpaid cash back for all cash back programs. 

  1. For example, if an account holder has earned rewards on qualifying transactions, but the rewards will not be deposited into their account until the end of the month, however the account is closed prior to the month’s end, terms should outline what happens to the account holder’s accrued rewards in an event like this, as well as whether or not the account holder will still be entitled to withdraw or redeem those rewards.

Conforming to Privacy Standards#

Since many Rewards Programs may require you using the bank transactional data for a purpose other than the purpose for which the bank/Unit is sharing the data, the terms for the program should disclose in detail: 

  1. The extent to which you will be leveraging bank data to inform the rewards earning and redemption process
  2. How the program will conform to current privacy standards and the Privacy Policy of your partner bank.
  3. Whether any additional information will need to be disclosed to the end-user that requires an opt-in or documented consent from the account holder in regards to privacy and data collection or data sharing. 
  4. Where applicable, you should also link to your existing privacy policy within the program terms for additional clarification.

Obtaining & Documenting User Consent for Data Sharing #

As it pertains to the collection and utilization of account holder transactional data, the terms should outline clearly the process involved in obtaining and using bank transactional data on the user’s behalf to provide them with the requested service, and the extent to which you will be storing and sharing this data. 

The terms should outline a clear mechanism for how you will obtain consent from the account holder to opt-in to this usage of their bank transactional data, as well as how you plan to document this consent for future audit purposes. 

This should appear in the Terms and Conditions for the rewards program and, as a best practice, on-screen during the sign-up flow.  

Privacy Policy #

In addition, your privacy policy should describe in more detail what information you are pulling for the program, how it will be used and stored, and whether it will be shared with third parties. The privacy practices will have to be reviewed by Unit and may require prior bank approval. 

If data is to be shared with third parties for purposes not subject to one of the Regulation P exclusions from notice and/or opt-out requirements, you will need to implement an opt-out process.

Implementation#

Now that you understand what is required to create rewards, you're ready to build rewards into your product. The Rewards API is simple and flexible, making it easy to implement and track rewards programs. Read the Rewards API documentation to learn how to implement rewards.

All Rewards programs must be reviewed and approved by Unit and the bank partner prior to launch.