Treasury and Issuing product marketing, design, and compliance guidelines

To offer and promote Stripe Treasury 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
• Required agreements and disclosures for Issuing
• Required agreements and disclosures for Treasury
• Required agreements and disclosures for fees, credits, and rewards programs
• Customer communications and documents
• Going live and marketing
• 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.

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.

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

Customer-facing dashboards

If your platform plans to allow connected accounts to store balances with multiple Treasury bank partners, display balances separately within any dashboard user interface or servicing communications that disclose balances. Provide a specific disclosure for each individual balance, indicating which bank holds the balance. This ensures that the connected account is aware of their potential insurance limits at each bank.

Required agreements and disclosures for Issuing

If you’re a platform and you’re not using Stripe-hosted onboarding, 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 Stripe Issuing Spend Card Program:

• Stripe Connected Account Agreement
• Stripe Issuing Accountholder Terms
• Issuing Bank Terms
  • Celtic Bank Users only: Issuing Bank Terms - Spend Card (Celtic Bank)
  • Cross River Bank Users only: Issuing Bank Terms - Spend Card (Cross River Bank)
• Apple Pay Terms (if enabled for your program)
  • Apple Pay Accountholder Terms

In addition to the above agreements, you must provide the following disclosures to your connected accounts before they can start using the Stripe 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 CA, 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)
    • Cross River Bank Users only: Commercial Financing Disclosure (Cross River Bank) (no fee)
  • For platforms that charge a $0.10 fee when creating cards for users:
    • Celtic Bank Users only: Commercial Financing Disclosure (Celtic Bank) (fee included)
    • Cross River Bank Users only: Commercial Financing Disclosure (Cross River Bank) (fee included)
  • 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, and you must submit custom commercial financing disclosures to 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.

Authorized User Agreements and Disclosures.

If you or your connected accounts create an individual type Cardholder, also known as an “authorized user,” you must present to cardholders—typically during the card activation process—the following agreements:

• Stripe E-Sign Disclosure
• Authorized User Terms
  • Celtic Bank Users only: Authorized User Terms (Celtic Bank)
  • Cross River Bank Users only: Authorized User Terms (Cross River Bank)

Charge card users

Connected Account Agreements and Disclosures.

You must provide the following agreements to your connected accounts before they can start using the Stripe Issuing Charge Card Program:

• Stripe Connected Account Agreement
• Stripe Issuing Accountholder Terms or Custom Platform Accountholder Terms
• Issuing Bank Terms
  • Celtic Bank Users only: Issuing Bank Terms - Charge Card (Celtic Bank)
  • Cross River Bank Users only: Issuing Bank Terms - Charge Card (Cross River Bank)
• Apple Pay Terms (if enabled for your program)
  • Apple Pay Accountholder Terms
• 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 Stripe 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 CA, NY, or UT, you must present your own custom commercial financing disclosure. You must report custom fees through Stripe’s Change Request Form, and you must submit custom commercial financing disclosures to platform-compliance@stripe.com. Both the custom fee and custom disclosure are subject to Stripe’s review and approval. Contact platform-compliance@stripe.com to assess the commercial financing disclosure requirements of your program.

Authorized User Agreements and Disclosures.

If you or your connected accounts create an individual type Cardholder, also known as an “authorized user,” you must present to cardholders—typically during the card activation process—the following agreements:

• Stripe E-Sign Disclosure
• Authorized User Terms
  • Celtic Bank Users only: Authorized User Terms (Celtic Bank)
  • Cross River Bank Users only: Authorized User Terms (Cross River Bank)

Commercial prepaid debit users

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

• Stripe Connected Account Agreement
• Stripe Issuing Accountholder Terms
• Issuing Bank Terms (Sutton Bank)

Authorized User Agreements and Disclosures.

If you or your connected accounts create an individual type Cardholder, also known as an “authorized user,” you must present to cardholders—typically during the card activation process—the following agreements:

• Stripe E-Sign Disclosure
• Sutton Bank Authorized User Terms

Required agreements and disclosures for Treasury

You must provide the following terms of service to your connected accounts and record their agreement before they can start using the Stripe Treasury Program:

• Stripe Services Agreement
• Stripe Treasury Terms - Connected Accounts

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 Treasury 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.

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 Treasury together, see Issuing regulated customer notices.

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 and marketing

The following information pertains to marketing and releasing your Stripe Treasury 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.

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 and to learn how to talk about FDIC pass-through insurance eligibility. 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 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 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.

Disclosures when marketing Treasury

If you offer Treasury 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.

• If you’re integrating with multiple Treasury bank partners, you must reference them all within your disclosure.

Disclosures when marketing both Treasury and Issuing

If you offer both Treasury 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 treasury banks 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 Change Request Form 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.

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 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.