# Source: https://docs.stripe.com/financial-accounts/connect/compliance.md

# Financial Accounts for platforms product marketing, design, and compliance guidelines

Learn how to keep your Financial Accounts for platforms program and marketing campaigns compliant.

> #### Legal Disclaimer
> 
> Don’t consider any of the information in this guide as legal advice. If you use Financial Accounts for platforms and Stripe Issuing, consult your own legal counsel for advice about product branding and using Stripe products to offer financial services.

This information applies to both Financial Accounts for platforms and Issuing integrations. To offer and promote Financial Accounts 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:

- [Account management](https://docs.stripe.com/financial-accounts/connect/compliance.md#account-management)
- [Required agreements and disclosures for Issuing](https://docs.stripe.com/financial-accounts/connect/compliance.md#issuing-terms)
- [Required agreements and disclosures for Financial Accounts for platforms](https://docs.stripe.com/financial-accounts/connect/compliance.md#treasury-terms)
- [Required agreements and disclosures for fees, credits, and rewards programs](https://docs.stripe.com/financial-accounts/connect/compliance.md#fees-credits-rewards-terms)
- [Customer communications and documents](https://docs.stripe.com/financial-accounts/connect/compliance.md#customer-communications-and-documents)
- [Going live and marketing](https://docs.stripe.com/financial-accounts/connect/compliance.md#going-live)
- [Recordkeeping](https://docs.stripe.com/financial-accounts/connect/compliance.md#recordkeeping)

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 [platform-compliance@stripe.com](mailto:platform-compliance@stripe.com).

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 [Change Request Form](https://form.asana.com/?k=8K51UWmWhttehNFD5qBLdg&d=974470123217835).

| Topic                         | Checklist                                                                                                                                                                                                             | Product applicability                        |
| ----------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------- |
| Application flow              | Your application flow:
  - Includes bank disclosures
  - Includes required agreements
  - Required KYC fields
  - Approved by Stripe Compliance                                                                       | Financial Accounts for platforms and Issuing |
| Fees and credits              | You’ve [submitted your planned fees and credits to Stripe](https://docs.stripe.com/financial-accounts/connect/compliance.md#fees-credits-rewards-terms)                                                               | Financial Accounts for platforms and Issuing |
| Marketing and user interfaces | Your marketing materials, including your website landing pages, dashboards, and support pages:
  - Are approved by Stripe Compliance (or align with messaging guidelines)
  - Include bank disclosures                | Financial Accounts for platforms and Issuing |
| Customer service channels     | Your customers can access your customer service channels and they can:
  - Submit complaints
  - Submit disputes                                                                                                      | Financial Accounts for platforms and Issuing |
| Account statements (optional) | If you choose to send account statements, they must:
  - Be approved by Stripe Compliance
  - Include Bank disclosures and relevant contact information                                                               | Financial Accounts for platforms             |
| Receipts                      | You have a mechanism to send your customers Stripe-generated money transmission receipts                                                                                                                              | Financial Accounts for platforms and Issuing |
| Regulated customer notices    | You send regulated customer notices to applicants and accountholders, and they’re either:
  - Sent by Stripe on your behalf
  - Sent by your platform with templates approved by Stripe Compliance                    | Issuing Spend Card and Charge Card           |
| Recordkeeping                 | You have a mechanism to retain copies of:
  - Customer consent to open accounts
  - Marketing materials and user interfaces
  - Customer communications, such as support emails
  - Account statements, if applicable | Financial Accounts for platforms and Issuing |

## Account management

Before you launch Financial Accounts 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 program guidance

Complaints are any expression of dissatisfaction with a product, service, policy, or employee related to Financial Accounts 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 [Handling complaints](https://docs.stripe.com/financial-accounts/connect/handling-complaints.md) guide for detailed complaint management requirements.

### Disputes and charge errors

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:

- You or your customer believe a charge is unauthorized
- You or your customer see an error on an account statement

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:

- Details about the authorized user
- Details about the disputed charge amount
- The transaction date
- An explanation of why the disputed charge is an error or unauthorized

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.

### Application flow

Your platform must provide for three main compliance requirement workflows:

- Collection of required KYC information
- Presentation of the required bank disclosure
- Ensuring that your applicant reads and accepts the required legal agreements

## Required agreements and disclosures for Issuing 

If you’re a platform and you’re not using [Stripe-hosted onboarding](https://docs.stripe.com/connect/hosted-onboarding.md), you must:

- Present the following program-specific agreements and disclosures for your connected accounts to accept when they open their account.
- Provide connected accounts with ongoing access to these agreements.
- Present each agreement separately. You can’t combine them into one agreement for your cardholders to accept.

*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:

- [Stripe Connected Account Agreement](https://stripe.com/legal/connect-account)
- [Stripe Issuing Accountholder Terms](https://stripe.com/legal/ssa-services-terms#stripe-issuing-accountholder-united-states)
- **Issuing Bank Terms**
  - *Celtic Bank Users only:* [Issuing Bank Terms - Spend Card (Celtic Bank)](https://stripe.com/legal/celtic-spend-card)
  - *Cross River Bank Users only:* [Issuing Bank Terms - Spend Card (Cross River Bank)](https://stripe.com/legal/issuing/crb-spend-card)
- **Apple Pay Terms** (if enabled for your program)
  - [Apple Pay Accountholder Terms](https://stripe.com/issuing/celtic/apple-payment-platform-program-manager-customer-terms-and-conditions/legal#exhibit-c-pass-through-provisions)

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:

- **Electronic Signature Consent**: You must include text near the “Issuing Bank Terms” link that states: “By clicking “submit application,” you agree to the Issuing Bank Terms, Stripe Connected Account Agreement, and Stripe Issuing Accountholder Terms, and you consent to electronic signatures as set forth in the Issuing Bank Terms.”
- **Commercial Financing Disclosure**: For Connected Accounts with a business address in NY or UT, you must present one of the following disclosures:
  - For platforms that don’t charge fees:
    - *Celtic Bank Users only:* [Commercial Financing Disclosure (Celtic Bank) (no fee)](https://stripe.com/legal/issuing-offer-document)
    - *Cross River Bank Users only:* [Commercial Financing Disclosure (Cross River Bank) (no fee)](https://stripe.com/legal/crb-issuing-offer-document)
  - For platforms that charge a $0.10 fee when creating cards for users:
    - *Celtic Bank Users only:* [Commercial Financing Disclosure (Celtic Bank) (fee included)](https://stripe.com/legal/issuing-offer-document-fees)
    - *Cross River Bank Users only:* [Commercial Financing Disclosure (Cross River Bank) (fee included)](https://stripe.com/legal/crb-issuing-offer-document-fees)
  - For platforms that charge fees other than a $0.10 fee when creating cards for users:
    - If you charge fees beyond Stripe’s fee of 0.10 USD, you might be required to create your own commercial financing disclosure to present to your connected accounts for creating virtual cards. You must report custom fees through Stripe’s [Change Request Form](https://form.asana.com/?k=8K51UWmWhttehNFD5qBLdg&d=974470123217835), and you must submit custom commercial financing disclosures to [platform-compliance@stripe.com](mailto:platform-compliance@stripe.com). Both the custom fee and custom disclosure are subject to Stripe’s review and approval. To assess the applicability of commercial financing disclosures to your program, contact [platform-compliance@stripe.com](mailto:platform-compliance@stripe.com).

*Authorized User Agreements and Disclosures.*

If you or your connected accounts create an `individual` type [Cardholder](https://docs.stripe.com/api/issuing/cardholders/object.md), also known as an “authorized user,” you must present to cardholders—typically during the card activation process—the following agreements:

- [Stripe E-Sign Disclosure](https://stripe.com/issuing/e-sign-disclosure/legal)
- Authorized User Terms
  - *Celtic Bank Users only:* [Authorized User Terms (Celtic Bank)](https://stripe.com/legal/issuing/celtic-authorized-user-terms)
  - *Cross River Bank Users only:* [Authorized User Terms (Cross River Bank)](https://stripe.com/legal/issuing/crb-authorized-user-terms)
  - *Fifth Third Bank Users only:* [Authorized User Terms (Fifth Third Bank)](https://stripe.com/legal/issuing/fifth-third-authorized-user-terms)

### Charge card users

*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:

- [Stripe Connected Account Agreement](https://stripe.com/legal/connect-account)
- [Stripe Issuing Accountholder Terms](https://stripe.com/legal/ssa-services-terms#stripe-issuing-accountholder-united-states) or Custom Platform Accountholder Terms
- **Issuing Bank Terms**
  - *Celtic Bank Users only:* [Issuing Bank Terms - Charge Card (Celtic Bank)](https://stripe.com/legal/celtic-charge-card)
  - *Cross River Bank Users only:* [Issuing Bank Terms - Charge Card (Cross River Bank)](https://stripe.com/legal/issuing/crb-charge-card)
  - *Fifth Third Bank Users only:* [Issuing Bank Terms - Charge Card (Fifth Third Bank)](https://stripe.com/legal/issuing/fifth-third-bank-terms)
- **Apple Pay Terms** (if enabled for your program)
  - [Apple Pay Accountholder Terms](https://stripe.com/issuing/celtic/apple-payment-platform-program-manager-customer-terms-and-conditions/legal#exhibit-c-pass-through-provisions)
- **Card Program Terms**: These are your bespoke program terms that supplement the Issuing Bank Terms. At a minimum, consider including the following items in your terms. Consult your legal counsel about which items to define within your own Card Program Terms.
  - Repayment methods, including automatic withdrawal consents
  - Billing cycles, including due dates
  - Fees
  - Rewards
  - Credit limits
  - Account closure requirements

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:

- **Electronic Signature Consent**: You must include text near the **Issuing Bank Terms** link stating that signing the Issuing Bank Terms signifies consent to electronic signatures and communications. For example, your message might read: “By clicking the submit application button, you agree to the Issuing Bank Terms, Stripe Connected Account Agreement, and Stripe Issuing Accountholder Terms; and you consent to electronic signatures as set forth in the Issuing Bank Terms.”
- **Commercial Financing Disclosure**: For connected accounts with a business address in NY or UT, you must present your own custom commercial financing disclosure. You must report custom fees through Stripe’s [Change Request Form](https://form.asana.com/?k=8K51UWmWhttehNFD5qBLdg&d=974470123217835), and you must submit custom commercial financing disclosures to [platform-compliance@stripe.com](mailto:platform-compliance@stripe.com). Both the custom fee and custom disclosure are subject to Stripe’s review and approval. Contact [platform-compliance@stripe.com](mailto:platform-compliance@stripe.com) to assess the commercial financing disclosure requirements of your program.

In the context of authorized user agreements and disclosures, if you or your connected accounts create an `individual` type [Cardholder](https://docs.stripe.com/api/issuing/cardholders/object.md), also known as an “authorized user,” you must present to cardholders—typically during the card activation process—the following agreements:

- [Stripe E-Sign Disclosure](https://stripe.com/issuing/e-sign-disclosure/legal)
- Authorized User Terms
  - *Celtic Bank Users only:* [Authorized User Terms (Celtic Bank)](https://stripe.com/legal/issuing/celtic-authorized-user-terms)
  - *Cross River Bank Users only:* [Authorized User Terms (Cross River Bank)](https://stripe.com/legal/issuing/crb-authorized-user-terms)
  - *Fifth Third Bank Users only:* [Authorized User Terms (Fifth Third Bank)](https://stripe.com/legal/issuing/fifth-third-authorized-user-terms)

### Commercial prepaid debit users

You must provide the following agreements to your connected accounts before they can start using your Issuing Commercial Prepaid Debit Card Program:

- [Stripe Connected Account Agreement](https://stripe.com/legal/ssa-services-terms#stripe-financial-accounts-for-platforms-formerly-stripe-treasury-connected-accounts)
- [Stripe Issuing Accountholder Terms](https://stripe.com/legal/issuing-accountholder)
- **Issuing Bank Terms**
  - *Sutton Bank users only*: [Issuing Bank Terms - Payout Card (Sutton Bank)](https://stripe.com/legal/issuing/sutton/payout-card-terms)
  - *Cross River Bank users only*: [Issuing Bank Terms - Commercial Prepaid Card (Cross River Bank)](https://stripe.com/legal/crb-commercial-prepaid-card)

In the context of authorized user agreements and disclosures, if you or your connected accounts create an `individual` type [Cardholder](https://docs.stripe.com/api/issuing/cardholders/object.md), also known as an “authorized user,” you must present to cardholders—typically during the card activation process—the following agreements:

- [Stripe E-Sign Disclosure](https://stripe.com/issuing/e-sign-disclosure/legal)
- **Authorized User Terms**
  - *Sutton Bank users only*: [Sutton Bank Authorized User Terms](https://stripe.com/legal/issuing/sutton-authorized-user-terms)
  - *Cross River Bank users only*: [Cross River Bank Authorized User Terms](https://stripe.com/legal/issuing/crb-authorized-user-terms)

## Required agreements and disclosures for Financial Accounts for platforms 

You must provide the following terms of service to your connected accounts and record their agreement before they can start using your Financial Accounts for platforms Program:

- [Stripe Services Agreement](https://stripe.com/legal/ssa)
- [Financial Accounts for platforms Terms - Connected Accounts](https://stripe.com/legal/ssa-services-terms#stripe-issuing-accountholder-united-states)

## Required agreements and disclosures for fees, credits, and rewards programs 

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 Financial Accounts 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 [Change Request Form](https://form.asana.com/?k=8K51UWmWhttehNFD5qBLdg&d=974470123217835).

## Customer communications and documents

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 Financial Accounts for platforms together, see [Issuing regulated customer notices](https://docs.stripe.com/issuing/compliance-us/issuing-regulated-customer-notices.md).

### Statements

Providing statements, while optional, is a best practice that allows your Financial Accounts for platforms or Issuing customers to periodically check their transaction history. If you send statements, make sure they contain the following information:

- [Company] name and address.
- Your company’s customer support contact number and website
- Customer account number
- Customer name and address
- Required disclosures
- Transaction history (including opening and closing balances for the statement period)
- Fees and credits.
- Information about how you resolve errors and complaints

### Receipts

One of the most important ongoing obligations you have in overseeing your Financial Accounts 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 [Regulatory receipts guide](https://docs.stripe.com/financial-accounts/connect/moving-money/regulatory-receipts.md) 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.

## Going live and marketing 

The following information pertains to marketing and releasing your Financial Accounts for platforms or Issuing programs to the public.

### General requirements for marketing your account offerings

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.

### UDAP and correct messaging

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.

| Do                                                                                                                                                                                                                                                                                                                                            | Don’t                                                                                                                                                                                        |
| --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Only use statements about products that are true, accurate, and aligned with how users engage with the products.                                                                                                                                                                                                                              | Don’t leave out key information from marketing content. If the information is likely to affect whether someone uses the product, then it’s “key."                                            |
| If you make claims that require additional data to support them, or if an end user needs to know more details to know how a certain claim is true, you must:
  - Provide documented evidence
  - Disclose that information                                                                                                                    | Make exaggerated claims that are hard to prove. Don’t make absolute statements that are disproved by a single exception. For example, “number 1," “every," “only," “all," “never," “always." |
| Clearly explain all qualifying limitations and requirements needed by end users to get the product or features that you’ve advertised.                                                                                                                                                                                                        | Don’t advertise features or programs that only a few applicants actually qualify for.                                                                                                        |
| All disclosures must meet a “clear and conspicuous” standard:
  - Font size must be large enough to read.
  - Font color must visibly contrast with the background.
  - Dynamic or video ads must have the disclosure on screen long enough to be read.                                                                                       | Don’t make disclosures hard to read.                                                                                                                                                         |
| Disclosures used to explain or modify a claim must be tied to the claim they’re explaining.
  - Use a hyperlink directly linking to the disclosure (or include the disclosure next to the claim in the copy itself)
  - Use reference text or symbols (an asterisk, for example) directly after the claim and before the disclosure language. | Don’t bury disclosures in other non-key disclosures or footnotes.                                                                                                                            |
| Disclose all account fees, costs, benefits, and terms as part of onboarding before your end users take out a product.                                                                                                                                                                                                                         | Don’t advertise products as “free” if you’re charging fees.                                                                                                                                  |
| Make sure all images used are properly licensed and that you can document this fact.                                                                                                                                                                                                                                                          | Don’t use images, formatting, or copy that implies products are endorsed by, or affiliated with, government entities or celebrities.                                                         |

### Messaging guidelines

Use the following suggested messaging guidelines to convey key aspects of Issuing, Financial Accounts 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.

- [Issuing](https://docs.stripe.com/financial-accounts/connect/compliance.md#issuing-messaging-guidelines)
- [Financial Accounts for platforms](https://docs.stripe.com/financial-accounts/connect/compliance.md#treasury-messaging-guidelines)

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 Financial Accounts for platforms or Issuing program.

#### Issuing messaging guidelines 

The following table provides guidelines for you to follow when developing messaging around your Issuing program.

| Topic category                                | Do                                                                                                                                                                                                                                                                                                             | Don’t                                                                                                                                                                                                                                                                                                                                                                                                       |
| --------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Logo and name usage                           | Your card program name and your brand name must have equal status, as with plain text: Widget balance® + Stripe. When referencing registered brand products, you must adhere to their separate brand guidelines. You only need to use the ®, ™, SM, mark once per asset.                                       | Don’t maintain unequal status between the card program name and your brand name:

  **Widget balance®** + Stripe                                                                                                                                                                                                                                                                                            |
| Comparison value propositions                 | Use language promoting the benefits of the card:
  - Better than cash
  - Safer than carrying cash
  - Manage your money hassle free
  - Spend only what you load
  - Spend only what you have on your card                                                                                                    | Don’t make disparaging remarks about other financial products or institutions: this includes debit, credit, bank accounts, banks, or other financial products used or issued by financial institutions. Don’t allude to prepaid card programs as superior to other card products with terms like:
  - Better than credit
  - Better than a bank account
  - No interest
  - No security deposit
  - No debt |
| Currency and using the funds                  | Use phrases like:
  - Access your contractor earnings
  - All [card program] cards are USD denominated
  - [Card program] cards can be used anywhere that accepts Visa cards                                                                                                                                   | Don’t use phrases like:
  - Access your wages
  - Get funds in any format you want
  - Can spend money across the world                                                                                                                                                                                                                                                                                     |
| What you can use the card for and limitations | Use phrases like:
  - Use [card program] for business needs
  - Get [card program] for your commercial needs
  - [Card program] can only be used for commercial purposes, and can’t be used for personal, family, or household purposes
  - Spend only what you load
  - Spend only what you have on your card | Don’t use phrases like:
  - Use [card program] for anything you want
  - Spend funds to buy the things you love
  - Personal cards
  - Use these cards like a payday loan, title loan, or pawn shop loan                                                                                                                                                                                                    |
| Where to spend funds                          | Use phrases like:
  - [Card program] can only be used for commercial purposes, and can’t be used for personal, family, or household purposes
  - Spend funds easily on your business                                                                                                                           | Don’t use phrases like:
  - Can be used just like a personal account
  - Get consumer cards
  - Spend funds to buy the things you love                                                                                                                                                                                                                                                                      |

#### Issuing messaging specifics per product

The following table provides guidelines for you to follow when developing messaging for specific cards in your Issuing program.

| Card                           | Do                                                                               | Don’t                                                                                                                                                                                        |
| ------------------------------ | -------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Spend card only                | Use phrases like:
  - …is a commercial credit program
  - A business credit card | Don’t use phrases like:
  - Debit card
  - Prepaid card
  - Better than a debit card                                                                                                         |
| Payout or prepaid account only | Use phrases like:
  - Money management account                                   | Don’t use phrases like:
  - Bank account
  - Deposit account
  - Checking account
  - Savings account
  - Similar terms to the previous ones that connote a traditional bank account product |

#### Financial Accounts for platforms messaging guidelines 

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:

- Business account
- Cash management account
- Financial account
- Money transfer account

See [Marketing Financial Accounts for platforms-based services](https://docs.stripe.com/financial-accounts/connect/marketing-financial-accounts.md) 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 [Stripe’s required FDIC pass-through insurance disclosure language](https://docs.stripe.com/financial-accounts/connect/marketing-financial-accounts.md#how-to-talk-about-fdic-pass-through-insurance-eligibility). Inaccurately referring to financial accounts as “bank accounts” could result in regulatory action, including fines.

| Category                                  | Do                                                                                                                                                                                                                                                                                                     | Don’t                                                                                                                                                                                                                                  |
| ----------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Logo and name usage                       | When referencing registered/® brand products, you must adhere to their separate brand guidelines. You only need to reference the ®, ™, SM mark once per asset.                                                                                                                                         | Don’t apply unequal status between the card program name and your brand name:

  **Widget balance®** + Stripe                                                                                                                          |
| Description of account value propositions | Use the following terms:
  - Business account
  - Cash management account
  - Financial account
  - Money transfer account                                                                                                                                                                             | Don’t use the following terms:
  - “Bank account”
  - “Deposit account”
  - “Checking account”
  - “Savings account”
  - Similar terms to the previous ones that imply a traditional bank account product, because Stripe isn’t a bank |
| FDIC insurance                            | Use the following terms that incorporate the term “eligible”:
  - “Eligible for FDIC pass-through insurance”
  - “Eligible for FDIC pass-through insurance up to the standard maximum deposit insurance per depositor in the same category"
  - “Eligible for FDIC pass-through insurance up to $250K” | Don’t use the following terms:
  - “FDIC insured”
  - “FDIC insured accounts”
  - “FDIC pass-through insurance guaranteed”                                                                                                             |

### CAN-SPAM

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:

- Misleading header information. Any email message, whether commercial or transactional, must not contain:
  - False or misleading header information.
  - A “from” line that doesn’t accurately identify any person (individual or business) who initiated the message.
  - Inaccurate or misleading identification of a protected computer used to initiate the message for purposes of disguising its origin.
- Deceptive subject headings. Any commercial email message must not contain deceptive subject headings. For example, a deceptive subject heading is one that likely misleads the recipient about a material fact regarding the message’s contents or subject matter.
- Opt-out mechanism. You must provide your customers with the ability to opt-out of receiving future commercial messages, and you must honor customer requests to opt-out within 10 days. You can’t require a user to pay a fee or provide information other than an email address to opt-out.
- Advertisement identification. Any commercial email message must contain clear and conspicuous identification that the message is an advertisement or solicitation.
- Physical address disclosure. Any commercial email message must disclose a valid physical address of the sender.

Failure to comply with CAN-SPAM could result in large fines for each violation.

### Testimonials

If you’re using testimonials or endorsements in advertising Stripe products to your users, consider the following:

- The person giving a testimonial must be a real person and a true, bona fide user of the service or product they’re talking about.
- You must obtain and keep their permission in writing to use their quote. You must update that permission every 24 months.
- Product benefits, costs, or features in any quotes must be verifiable and true to what most users can expect to get.
- If you paid someone for their quote, or gave them anything of value, you must put a disclaimer near the quote stating this fact. This includes paid actors, if their scripting makes it sound like they’re giving a testimonial.

### Prohibited advertising

You can’t advertise Issuing or Financial Accounts 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.

### Prohibition on international marketing

Financial Accounts for platforms isn’t available to users or merchants located outside the US, so limit all marketing for Financial Accounts 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.

### Required marketing disclosures

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:

#### Disclosures when marketing Issuing

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:

- The name for your card program (for example, Rocket Rides Corporate Card).
- The relevant statement from the following table identifying the issuing bank. It can be in the footers section of your materials; however, the font must be a legible size and a contrasting color to the background.

| Statement for Celtic Bank users                                                             | Statement for Sutton Bank users                                                                                           | Statement for Cross River Bank users (Charge Card)                            | Statement for Cross River Bank users (Commercial Prepaid)                    | Statement for Fifth Third Bank users                                                |
| ------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------------------- | ---------------------------------------------------------------------------- | ----------------------------------------------------------------------------------- |
| [Card Program Name] Visa® Commercial cards are powered by Stripe and issued by Celtic Bank. | [Card Program Name] Visa® Prepaid Cards are issued by Sutton Bank®, Member FDIC, pursuant to a license from Visa USA Inc. | [Card Program Name] Charge Cards are issued by Cross River Bank, Member FDIC. | [Card Program Name] Debit Cards are issued by Cross River Bank, Member FDIC. | [Card Program Name] Charge Cards are issued by Fifth Third Bank, N.A., Member FDIC. |

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

| Statement for Issuing Spend Card users                                                                                                                          |
| --------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Stripe Issuing balances are provided in the US by Stripe Payments Company, licensed money transmitter, with funds held at Stripe’s bank partners, Members FDIC. |

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.

| Statement for Commercial Prepaid Debit Users                                                                                                                                |
| --------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Commercial Prepaid Account balances are provided in the US by Stripe Payments Company, licensed money transmitter, with funds held at Stripe’s bank partners, Members FDIC. |

#### Disclosures when marketing Financial Accounts for platforms

If you offer Financial Accounts 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:

- A statement that you’re neither a bank nor a money transmitter.
- Statement of partnership with Stripe.
- “Stripe Payments Company” must be hyperlinked and point to `https://stripe.com`.

| Statement for Fifth Third bank users                                                                                                                                                    |
| --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| [Company Name] partners with [Stripe Payments Company](https://stripe.com/) for money transmission services and account services with funds held at Fifth Third Bank N.A., Member FDIC. |

#### Disclosures when marketing both Financial Accounts for platforms and Issuing

If you offer both Financial Accounts 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:

- A name for your card program (for example, Rocket Rides Corporate Card).
- A combined statement identifying both the issuing and Financial Accounts banks and saying that you’re neither a bank nor a money transmitter.

| Example combined statement                                                                                                                                                                                                                                                  |
| --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| [Company Name] partners with [Stripe Payments Company](https://stripe.com/) for money transmission services and account services with funds held at Fifth Third Bank, N.A., Member FDIC. [Card Program Name] Visa® Prepaid Cards are issued by [Issuing bank], Member FDIC. |

### Materials submission

Submit copies of your marketing materials and user interface mockups through our [Change Request Form](https://form.asana.com/?k=8K51UWmWhttehNFD5qBLdg&d=974470123217835) 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 going live. Our team of compliance specialists reviews them with our bank partners and responds within 10 business days.

When submitting your materials:

- Provide full screenshots of product pages that include headings and footers.
- The preferable format for materials is PDF, however any format where all text is legible is acceptable.
- Describe the types of marketing material you’re submitting (for example, web banners, emails, search engine marketing, and whether it’s only text or images and text).
- You can send up to 5 attachments per submission.

Send any additional questions to our team at [platform-compliance@stripe.com](mailto:platform-compliance@stripe.com).

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 Financial Accounts for platforms or Issuing capabilities.

## Recordkeeping

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.

| Record type                            | Example form of records                                                                                                                                                 |
| -------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Product user experience                | Screenshots of all deployed versions of the product user experience and their deployment dates. Include application flow, customer dashboard, support pages, and so on. |
| Marketing                              | Inventory of all marketing copy deployed, email distribution lists used, and email solicitation opt-out lists, including timestamps of user opt-outs.                   |
| Customer communications and complaints | Email interactions and documentation developed in the course of resolving complaints.                                                                                   |
| Receipts                               | Receipts provided by Stripe and evidence that they’re uploaded to the customer’s Dashboard.                                                                             |
| Customer statements                    | Historical statements generated and made available to customers for download.                                                                                           |

## See also

- [Regulatory receipts](https://docs.stripe.com/financial-accounts/connect/moving-money/regulatory-receipts.md)
- [Handling complaints](https://docs.stripe.com/financial-accounts/connect/handling-complaints.md)
- [Marketing Financial Accounts for platforms](https://docs.stripe.com/financial-accounts/connect/marketing-financial-accounts.md)