Treasury and Issuing product marketing, design, and compliance guidelines

To offer and promote Stripe Treasury and Issuing products to your users, 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 by the following components:

• Account management
• Going live
• Recordkeeping

The following table outlines the steps you must complete before onboarding your first connected account users. If you need help, contact the Stripe Compliance team at platform-compliance@stripe.com.

Account management

You need the proper internal compliance controls before launching Stripe Treasury or Stripe Issuing. 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 Stripe Treasury or Stripe Issuing, except those expressions made by employees of your company. Properly handling complaints is mandatory when offering financial services products. See the Handling complaints 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

If you’re not using Stripe Hosted Onboarding, you must present the following agreements for your users to accept during their account opening process. You must also provide ongoing access to these agreements after your users open an account.

Issuing only

Connect account agreements

• Stripe Connected Account Agreement
• Stripe Issuing Accountholder Terms
• Apple Pay Terms (if applicable)
• Spend Card users:
  • Issuing Bank Terms (Celtic Bank)
    When surfacing the “Issuing Bank Terms” for Spend Card, you must include surrounding copy that states the Issuing Bank Terms include consent to electronic signatures and communications. For example, your message to users might read: “By clicking the submit application button, you agree to the Issuing Bank Terms, Stripe Connected Account Agreement, Stripe Issuing Accountholder Terms, and you consent to electronic signatures as set forth in the Issuing Bank Terms.”
• Commercial prepaid debit users:
  • Sutton Issuing Bank Terms (Sutton Bank)

Authorized user agreements

After your connected account owners create cards for their authorized users, you need to make sure those authorized users accept the following agreements, typically during the card activation process.

• Stripe E-Sign Disclosure
• Spend Card users:
  • Spend Card Authorized User Terms
  • Celtic Bank Privacy Policy
  • Apple Pay Terms (if enabled, only Exhibit C applies to your users)

Treasury only

• Stripe Services Agreement
• Stripe Treasury Terms - connected accounts

Treasury and Issuing

Connect account agreements

• Stripe Connected Account Agreement
• Stripe Treasury & Issuing Accountholder Terms
• Apple Pay Terms (if applicable)
• Spend Card users:
  • Issuing Bank Terms (Celtic Bank)
    When surfacing the “Issuing Bank Terms” for Spend Card, you must include surrounding copy that states the Issuing Bank Terms include consent to electronic signatures and communications. For example, your message to users might read: “By clicking the submit application button, you agree to the Issuing Bank Terms, Stripe Connected Account Agreement, Stripe Issuing Accountholder Terms, and you consent to electronic signatures as set forth in the Issuing Bank Terms.”
• Commercial prepaid debit users:
  • Sutton Issuing Bank Terms (Sutton Bank)

Authorized user agreements

After your connected account owners create cards for their authorized users, you need to make sure those authorized users accept the following agreements, typically during the card activation process.

• Stripe E-Sign Disclosure
• Spend Card users:
  • Spend Card Authorized User Terms
  • Celtic Bank Privacy Policy
  • Apple Pay Terms (if enabled, only Exhibit C applies to your users)

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 Treasury or Issuing program.

You’re required to report to Stripe the amount of any fees and credits that you plan to offer your users. This helps ensure 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 Fee Intake Form to report all fees, credits, and rewards programs.

Account closure notices

When you receive account closure requests, communicate important details about your customer’s account closure with an account closure notice email to Stripe. You need to include several important details in your account closure notices:

• The date that your customer’s account was closed.
• Confirmation that your customer’s account balance was 0.00 USD when it was closed.
• Where you’ll send any funds to your customer’s account after it’s closed.

Statements

Providing statements, while optional, is a best practice that allows your Treasury 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 Treasury 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 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

The following information pertains to releasing your Stripe Treasury or Issuing programs to the public.

Marketing your account offerings-general requirements

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.

Messaging guidelines

Use the following suggested messaging guidelines to convey key aspects of Stripe Issuing, Stripe Treasury, 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
• Treasury

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 or Issuing program.

Issuing messaging guidelines

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

Issuing messaging specifics per product

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

Treasury 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 Treasury-based services for a full list of terms you can and can’t use to describe your accounts. Inaccurately referring to Treasury accounts as “bank accounts” could result in regulatory action, including fines.

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 Stripe Issuing or Treasury, in any print, radio, TV, on the internet, or any other digital format that promotes any unlawful activity or causes reputation concerns for Stripe or our bank partners.

Prohibition on international marketing

Treasury isn’t available to users or merchants located outside the US, so limit all marketing for Treasury to US domestic audiences.

For Issuing, although you may ship cards to international addresses for US-domiciled cardholders, you must not engage in marketing the Issuing program internationally or to persons located outside of the United States. This 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, you must comply with card network rules in connection with marketing activities.

Required 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:

Issuing

Issuing users must include the following information in an easily discoverable and accessible area on all marketing materials, account opening flows, and all product pages or 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, it must be a legible font size and a contrasting color to the background.

Treasury

Treasury users must include the following information in an easily discoverable and accessible area on marketing materials, account opening flows, and all product pages or 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.

Treasury and Issuing

If you’re using both Treasury and Issuing connected products, you must include the following information in an easily discoverable and accessible area on all marketing materials, account opening flows, and product surfaces:

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

Materials submission

Submit copies of your marketing materials and user interface mockups through our Review Intake Form for review before you launch. Our team of compliance specialists reviews them with our bank partners and responds within 10 business days.

When submitting your materials:

• Provide full screenshots or product pages that include headings and footers.
• The preferable format for materials is PDF, however any format where all text is legible is acceptable.
• You will be asked what type of marketing material you’re submitting (for example, web banners, emails, search engine marketing, if marketing text only or images and text).
• You can send up to 5 attachments per submission.

Additional questions can be sent to our team at 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.

Recordkeeping

To demonstrate your adherence to the requirements listed in this guide, we ask that you 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, and examples of what could constitute a record.