This information applies to both Treasury for platforms and Issuing integrations. To offer and promote Treasury for platforms and Issuing products to your customers and connected accounts, your marketing and user interfaces must adhere to the guidelines that we outline here. These guidelines help you navigate the financial regulations that apply to Stripe products. We’ve organized them into the following sections:
The following table outlines the steps you must complete before onboarding your first connected accounts. If you need help, contact the Stripe Compliance team at .
If you make changes to any items in the table at a later date, you must submit a request to the Stripe Compliance team using the .
Before you launch Treasury for platforms or Issuing, you must implement the proper internal compliance controls. You also need to build the processes described in this section into your various workflows, customer service, and product channels.
Complaints are any expression of dissatisfaction with a product, service, policy, or employee related to Treasury for platforms or Issuing, except those expressions made by employees of your company. Properly handling complaints is mandatory when offering financial services products. See the guide for detailed complaint management requirements.
As part of providing customer support, you might be notified of suspected disputed charges, charge errors, or both. The two most common types of disputes or errors are:
If these errors occur, submit the dispute through the Stripe Dashboard. Select the relevant transactions and choose Dispute. Be prepared to provide Stripe with specific information to investigate the dispute, such as:
You must report any disputed charge or error immediately upon notification of it. Failure to do so might impact your financial liability. To avoid a sustained reduction to your available balance, you can pay the disputed charge while we determine the validity of the dispute. If Stripe deems the dispute valid, we credit the disputed charge amount back to the appropriate account.
Your platform must provide for three main compliance requirement workflows:
If you’re a platform and you’re not using , you must:
Connected Account Agreements and Disclosures.
You must provide the following agreements to your connected accounts before they can start using the Issuing Spend Card Program:
In addition to the above agreements, you must provide the following disclosures to your connected accounts before they can start using the Issuing Spend Card Program:
Authorized User Agreements and Disclosures.
If you or your connected accounts create an individual type , also known as an “authorized user,” you must present to cardholders—typically during the card activation process—the following agreements:
Connected Account Agreements and Disclosures.
You must provide the following agreements to your connected accounts before they can start using the Issuing Charge Card Program:
In addition to the above agreements, you must provide the following disclosures to your connected accounts before they can start using the Issuing Spend Card Program:
In the context of authorized user agreements and disclosures, if you or your connected accounts create an individual type , also known as an “authorized user,” you must present to cardholders—typically during the card activation process—the following agreements:
You must provide the following agreements to your connected accounts before they can start using your Issuing Commercial Prepaid Debit Card Program:
In the context of authorized user agreements and disclosures, if you or your connected accounts create an individual type , also known as an “authorized user,” you must present to cardholders—typically during the card activation process—the following agreements:
You must provide the following terms of service to your connected accounts and record their agreement before they can start using your Treasury for platforms Program:
In addition to the previous agreements, your terms of service and fee schedule must clearly outline the fees and terms that you implement as part of your Treasury for platforms or Issuing program.
You must report to Stripe the details of any fees, credits, and rewards programs that you plan to offer. That helps make sure your user interfaces and marketing materials are compliant with financial regulations regarding fees or offer credits, especially in the form of rewards programs. Use the .
To comply with applicable laws and regulations, you must send certain communications to both your applicants and accountholders upon certain trigger events.
To learn about customer communication requirements when using Issuing and Treasury for platforms together, see .
Providing statements, while optional, is a best practice that allows your Treasury for platforms or Issuing customers to periodically check their transaction history. If you send statements, make sure they contain the following information:
One of the most important ongoing obligations you have in overseeing your Treasury for platforms or Issuing program is providing your customers with money transmissions receipts. Every regulated transaction your customers initiate generates a compliant money transmission receipt URL that you must share with your customer. You can provide these URL receipts in a few different ways, such as emailing them or making them available in your customer’s Dashboard. See the for more information on how to access hosted receipts. If you plan to charge your connected account owners any fees, whether they’re transactional or monthly recurring, include a description of the fee on the receipt so that they can reconcile it to corresponding transactions or monthly statements.
The following information pertains to marketing and releasing your Treasury for platforms or Issuing programs to the public.
Any message or communication you provide to the public for financial products or services they don’t currently use must be truthful and fair, and in the interest of your potential customers.
Federal regulation prohibits unfair and deceptive acts or practices (UDAP). To avoid UDAP violations, you must think of the end user first when developing and deploying any marketing materials.
Make sure that marketing materials use clear messaging that fully explains product features, costs, benefits, and limitations. Don’t leave out key terms or fees, and don’t advertise product uses or features that aren’t true.
Use the following suggested messaging guidelines to convey key aspects of Issuing, Treasury for platforms, or both programs. Stripe or our banking partners have validated (proven as true) this content, so you can confidently use this messaging in user-facing materials.
The following tables include validated content you can provide in your marketing campaigns. You can make non-substantive changes (for example, changing the design or infusing your brand’s voice) to the suggested messaging as long as the key information remains the same. Any substantive deviations from these guidelines require you to submit marketing materials and get approval from Stripe and our bank partners. Approvals might take up to 10 business days to process.
You’re responsible for training employees on these requirements if they engage in marketing or sales activities for your Treasury for platforms or Issuing program.
The following table provides guidelines for you to follow when developing messaging around your Issuing program.
The following table provides guidelines for you to follow when developing messaging for specific cards in your Issuing program.
Don’t use words like “bank account,” “deposit account," “checking account,” “savings account,” or similar terms that imply a traditional bank account product because Stripe isn’t a bank. Pre-approved terms include the following:
See for a full list of terms you can and can’t use to describe your accounts and to learn how to talk about FDIC pass-through insurance eligibility. If you’re planning to describe FDIC pass-through insurance at all, your content must include . Inaccurately referring to financial accounts as “bank accounts” could result in regulatory action, including fines.
The CAN-SPAM Act regulates marketing activity conducted by email. An email is deemed a commercial message, subject to the CAN-SPAM act, if the primary purpose of the email is to convey a commercial advertisement, or to promote a product or service. A transactional email is an email sent to a customer that has a primary purpose relating to a particular transaction or relationship between you and the customer, such as a payment reminder. The CAN-SPAM Act imposes more rigorous requirements on commercial email messages, as compared with transactional messages. Transactional messages aren’t subject to most of the requirements of the CAN-SPAM Act. If a message contains both transactional content and commercial content, the CAN-SPAM Act commercial email requirements might apply, if the primary purpose of the message can be considered commercial.
To facilitate compliance with the CAN-SPAM Act, any employee or staff using or having access to your email systems and resources for marketing must adhere to the following guidelines:
Failure to comply with CAN-SPAM could result in large fines for each violation.
If you’re using testimonials or endorsements in advertising Stripe products to your users, consider the following:
You can’t advertise Issuing or Treasury for platforms in print, radio, TV, on the internet, or in any other format in a manner that promotes any unlawful activity or that causes reputation concerns for Stripe or our bank partners.
Treasury for platforms isn’t available to users or merchants located outside the US, so limit all marketing for Treasury for platforms to US domestic audiences.
For Issuing, although you can ship cards to international addresses for US-domiciled cardholders, you must not market the Issuing program internationally or to persons outside of the United States. That includes advertising or promoting Issuing through marketing channels such as social media, email, and paid search results. As with all other aspects of the Issuing program, your marketing activities must comply with card network rules.
Your users must understand the role that Stripe’s bank partners play in offering and operating certain financial products—and in many cases, that they’re entering into a contractual relationship with these banks. Your users must also understand the material costs and fees associated with their use of each financial product. We require you to build the following disclosures into your marketing materials:
If you offer Issuing products, you must include the following information in an easily discoverable and accessible area on all marketing materials, account opening flows, and product interfaces:
In addition to the disclosures above, if you offer an Issuing Spend Card, you must also include the following statement. You can place it in the footers section of your materials, but the font must be a legible size and have a contrasting color as the background
In addition to the disclosures above, if you offer a Commercial Prepaid Debit Card, you must also include the following statement. You can place it in the footers section of your materials, but the font must be a legible size and have a contrasting color as the background.
If you offer Treasury for platforms products, you must include the following information in an easily discoverable and accessible area on all marketing materials, account opening flows, and product interfaces:
- “Stripe Payments Company” must be hyperlinked and point to
https://stripe..com
If you offer both Treasury for platforms and Issuing products, you must include the following information in an easily discoverable and accessible area on all marketing materials, account opening flows, and product interfaces:
Submit copies of your marketing materials and user interface mockups through our for review before you launch. If you make any changes to marketing materials, application flows, or user communications, Stripe’s compliance team must perform a review before you go live. Our team of compliance specialists reviews them with our bank partners and responds within 10 business days.
When submitting your materials:
Send any additional questions to our team at .
We might request that you change your marketing materials to comply with regulatory requirements. If we request a change, it’s your responsibility to update the materials and provide evidence of the change to Stripe. Failure to update materials at our request might result in Stripe disabling your Treasury for platforms or Issuing capabilities.
You must demonstrate your adherence to the requirements listed in this guide. Keep thorough records of all marketing materials, customer data, account information, and other disclosures you make to customers for at least 5 years. The following is a list of all records to keep, with examples of record types.
