{"_id":"5bc1245e33048700032f7d9c","project":"59f79e3c584eb200345ceafc","version":{"_id":"5ba178b00a916500030c6a21","project":"59f79e3c584eb200345ceafc","__v":24,"forked_from":"59f79e3c584eb200345ceaff","createdAt":"2015-09-17T03:47:20.956Z","releaseDate":"2015-09-17T03:47:20.956Z","categories":["5ba178b00a916500030c69a2","5ba178b00a916500030c69a3","5ba178b00a916500030c69a4","5ba178b00a916500030c69a5","5ba178b00a916500030c69a6","5ba178b00a916500030c69a7","5ba178b00a916500030c69a8","5ba178b00a916500030c69a9","5ba178b00a916500030c69aa","5ba178b00a916500030c69ab","5ba178b00a916500030c69ac","5afb6888212c690003ae3d3b","5ba178b00a916500030c69ad","5ba178b00a916500030c69ae","5ba2dcbc99f53f0003b97e2c","5babd73fa0ab3e0003ead030","5bb4038be7222e000334dd97","5bb55954478c1300031a44c2","5bb665a1607307000327c81e","5bb6f90229a7fb0003a0650d","5bb7f9bc29a7fb0003a07ac1","5bba58bd7ba7710003bd901d","5bba6dac7ba7710003bd908d","5bba6e257ba7710003bd9090","5bbac87810189c0003e619ea","5bbb9d02b5862c00036266b2","5bbbadb6219c3e000376c2de","5bc417751d1b0000182bf7f6","5bc59e3b2a5b4f0044db5b97","5bc7bbce2262cc0041f6eff2","5bce6a3580a7250031199f34","5bcfac2c4082510019f2d91b","5bcfac3757bed90030e45d68","5bcfac45d305bc0049941539","5bd2a43548bb6f00289c8fad","5bd3a42a026ebe001f66259e","5bd9d5afffe003005b02f97b","5becb7ee85c6b300557662b6"],"is_deprecated":false,"is_hidden":false,"is_beta":true,"is_stable":false,"codename":"","version_clean":"3.2.0","version":"3.2"},"category":{"_id":"5bb6f90229a7fb0003a0650d","project":"59f79e3c584eb200345ceafc","version":"5ba178b00a916500030c6a21","__v":0,"sync":{"url":"","isSync":false},"reference":false,"createdAt":"2018-10-05T05:39:14.461Z","from_sync":false,"order":10,"slug":"interest-bearing-accounts","title":"Interest Bearing Accounts"},"user":"5bbfeeea7f922a0003f04c65","__v":0,"parentDoc":null,"updates":[],"next":{"pages":[],"description":""},"createdAt":"2018-10-12T22:46:54.987Z","link_external":false,"link_url":"","sync_unique":"","hidden":false,"api":{"results":{"codes":[]},"settings":"","auth":"required","params":[],"url":""},"isReference":false,"order":5,"body":"Interest Bearing Deposit Accounts are non-transactional savings accounts which accrue interest, and should be marketed as such.\n\n##Marketing Representations\nMarketing of interest bearing deposit accounts must comply and follow all guidelines of the appropriate regulatory bodies. Enforcement actions may be brought upon by:\n* The Federal Trade Commission (“FTC”)\n* Consumer Financial Protection Bureau (“CFPB”)\n\nThe platform will adhere to the following verbiage and placement requirements, also detailed in the Marketing/Disclosure Guidelines. Additionally, the Platform will not reference SynapseFI or Evolve Bank & Trust in any other way without express written permission from the respective entity.\n\nThe Platform’s disclosures will include language describing their relationship to SynapseFI and Evolve Bank & Trust similar to:\n\n*“The Platform uses SynapseFI, our third-party bank software provider and agent of Evolve Bank & Trust, Member FDIC, to open these accounts.”*\n\n##Upon Opening an Interest Bearing Deposit Account\nIf a User is opening an interest bearing deposit account (IB-DEPOSIT-US Node), include a checkbox and the following verbiage on the page the User is created:\n\n*“The bank services are provided by Evolve Bank & Trust, Member FDIC. By opening a deposit account on <Insert Platform Name>, you agree to Evolve Bank & Trust’s Deposit Agreement.”*\n\nThe following word shall be a hyperlink to the Platforms custom Deposit Agreement:\t“Deposit Agreement” ­ https://synapsefi.com/evolve­bank­deposit­agreement\n\n##Contact Information\nInclude our contact information on your customer support page. \n\n*\"Bank services are provided through our banking software provider, SynapseFI. To report a complaint relating to the bank services, email help:::at:::synapsefi.com.”*\n\n##Truth in Savings Disclosure\nDeposit accounts must be accompanied by a Regulation DD compliant Truth in Savings disclosure\nFor specific requirements, see: [12 CFR 230](https://www.gpo.gov/fdsys/granule/CFR-2012-title12-vol4/CFR-2012-title12-vol4-sec230-4 ) \n\nA Regulation DD compliant Truth in Savings disclosure will be provided, clearly stating terms and conditions, including interest rates. As stated above, this account earns interest paid by Evolve Bank & Trust, therefore the following terms may be used for interest paid by Evolve Bank & Trust only:\nInterest\n* Yield\n* Annual Percentage Rate (“APR”)\n* Annual Percentage Yield (“APY”)\n\nIf the client intends to add supplemental incentives to the interest rate paid by Evolve Bank & Trust, the rates must be distinguished from one another, and disclosed separately. Only the following terms may be used to market any incentive not paid by Evolve Bank & Trust: \n* Reward\n* Rebate\n* Bonus - provided that [CFPB’s definition](https://www.consumerfinance.gov/eregulations/1030-2/2011-31727#1030-2-b-2) is met\n\nIf user is to receive interest payments through a separate commercial agreement between platform and a financial institution, other than Evolve Bank & Trust, SynapseFI must be made aware. Additionally, the Truth in Savings agreement must be compliant, easily accessible, and clearly separate from the marketing of services that SynapseFI provides to platform. It is the platform's responsibility to comply with all Truth in Savings requirements/regulations if contracting with a third party financial institution. It is also the platform’s responsibility to avoid any language or claims that would mislead a user to believe services or products provided by a third party are provided by Synapse or Synapse’s banking partners.\n\n##Legal Agreements Accessibility\nAll disclosures, agreements, and policies required for creating a new Interest Bearing Deposit Account must be compiled in a central location, and easily accessed by the Users. This may be accomplished by one of the following:\n\n* Include links to each document in a header or footer within your website or application.\nCompile all documents on a legal landing page, clearly labeled and easily found on the website or application.\n* Compile all documents within a “settings”, or similar, page under the User’s profile.\n\nIf a User must have login credentials to access this information, the TOS, Privacy Policies, and Agreements must be emailed to the User, once they agree, so that they maintain access to the documents in the event they close their account.\n\n##FDIC Insurance\nThe platform will not claim to be FDIC insured directly, the accounts are insured through Evolve Bank & Trust. Account insurance coverage is subject to FDIC rules and limitations. \n\nFor all pages including references to transactions or funds held in a User’s Deposit Account, or bank services in the Deposit Agreement, include the following the the footer of the webpage and/or application screen.\n\t\t\t\t\t\t\n*“Banking services are provided by Evolve Bank & Trust, Member FDIC.”*\n\n##Endorsements\nThe use of endorsements and testimonials in advertising is subject to the same UDAAP laws as any direct marketing by the Platform. The FTC has released additional guidance, to which the Platform is required to adhere. SynapseFI strongly suggests screening procedures are put implemented to ensure any endorsements or testimonials comply with the FTC’s final guide. See: [16 CFR Part 255](https://www.ftc.gov/sites/default/files/attachments/press-releases/ftc-publishes-final-guides-governing-endorsements-testimonials/091005revisedendorsementguides.pdf).\n\nAdditionally, the FTC has responded to questions regarding endorsements. [See here for guidance.](https://www.ftc.gov/tips-advice/business-center/guidance/ftcs-endorsement-guides-what-people-are-asking)\n\n##Monthly Statements\nTo give users full visibility into their account activity, please send monthly statements to users using our [Statements API](https://docs.synapsefi.com/v3.2/docs/statements-intro).","excerpt":"Legal disclosures for the Interest Bearing Account","slug":"legal-disclosures-5","type":"basic","title":"Legal Disclosures (IB-DEPOSIT-US)"}

Legal Disclosures (IB-DEPOSIT-US)

Legal disclosures for the Interest Bearing Account

Interest Bearing Deposit Accounts are non-transactional savings accounts which accrue interest, and should be marketed as such. ##Marketing Representations Marketing of interest bearing deposit accounts must comply and follow all guidelines of the appropriate regulatory bodies. Enforcement actions may be brought upon by: * The Federal Trade Commission (“FTC”) * Consumer Financial Protection Bureau (“CFPB”) The platform will adhere to the following verbiage and placement requirements, also detailed in the Marketing/Disclosure Guidelines. Additionally, the Platform will not reference SynapseFI or Evolve Bank & Trust in any other way without express written permission from the respective entity. The Platform’s disclosures will include language describing their relationship to SynapseFI and Evolve Bank & Trust similar to: *“The Platform uses SynapseFI, our third-party bank software provider and agent of Evolve Bank & Trust, Member FDIC, to open these accounts.”* ##Upon Opening an Interest Bearing Deposit Account If a User is opening an interest bearing deposit account (IB-DEPOSIT-US Node), include a checkbox and the following verbiage on the page the User is created: *“The bank services are provided by Evolve Bank & Trust, Member FDIC. By opening a deposit account on <Insert Platform Name>, you agree to Evolve Bank & Trust’s Deposit Agreement.”* The following word shall be a hyperlink to the Platforms custom Deposit Agreement: “Deposit Agreement” ­ https://synapsefi.com/evolve­bank­deposit­agreement ##Contact Information Include our contact information on your customer support page. *"Bank services are provided through our banking software provider, SynapseFI. To report a complaint relating to the bank services, email [email protected]”* ##Truth in Savings Disclosure Deposit accounts must be accompanied by a Regulation DD compliant Truth in Savings disclosure For specific requirements, see: [12 CFR 230](https://www.gpo.gov/fdsys/granule/CFR-2012-title12-vol4/CFR-2012-title12-vol4-sec230-4 ) A Regulation DD compliant Truth in Savings disclosure will be provided, clearly stating terms and conditions, including interest rates. As stated above, this account earns interest paid by Evolve Bank & Trust, therefore the following terms may be used for interest paid by Evolve Bank & Trust only: Interest * Yield * Annual Percentage Rate (“APR”) * Annual Percentage Yield (“APY”) If the client intends to add supplemental incentives to the interest rate paid by Evolve Bank & Trust, the rates must be distinguished from one another, and disclosed separately. Only the following terms may be used to market any incentive not paid by Evolve Bank & Trust: * Reward * Rebate * Bonus - provided that [CFPB’s definition](https://www.consumerfinance.gov/eregulations/1030-2/2011-31727#1030-2-b-2) is met If user is to receive interest payments through a separate commercial agreement between platform and a financial institution, other than Evolve Bank & Trust, SynapseFI must be made aware. Additionally, the Truth in Savings agreement must be compliant, easily accessible, and clearly separate from the marketing of services that SynapseFI provides to platform. It is the platform's responsibility to comply with all Truth in Savings requirements/regulations if contracting with a third party financial institution. It is also the platform’s responsibility to avoid any language or claims that would mislead a user to believe services or products provided by a third party are provided by Synapse or Synapse’s banking partners. ##Legal Agreements Accessibility All disclosures, agreements, and policies required for creating a new Interest Bearing Deposit Account must be compiled in a central location, and easily accessed by the Users. This may be accomplished by one of the following: * Include links to each document in a header or footer within your website or application. Compile all documents on a legal landing page, clearly labeled and easily found on the website or application. * Compile all documents within a “settings”, or similar, page under the User’s profile. If a User must have login credentials to access this information, the TOS, Privacy Policies, and Agreements must be emailed to the User, once they agree, so that they maintain access to the documents in the event they close their account. ##FDIC Insurance The platform will not claim to be FDIC insured directly, the accounts are insured through Evolve Bank & Trust. Account insurance coverage is subject to FDIC rules and limitations. For all pages including references to transactions or funds held in a User’s Deposit Account, or bank services in the Deposit Agreement, include the following the the footer of the webpage and/or application screen. *“Banking services are provided by Evolve Bank & Trust, Member FDIC.”* ##Endorsements The use of endorsements and testimonials in advertising is subject to the same UDAAP laws as any direct marketing by the Platform. The FTC has released additional guidance, to which the Platform is required to adhere. SynapseFI strongly suggests screening procedures are put implemented to ensure any endorsements or testimonials comply with the FTC’s final guide. See: [16 CFR Part 255](https://www.ftc.gov/sites/default/files/attachments/press-releases/ftc-publishes-final-guides-governing-endorsements-testimonials/091005revisedendorsementguides.pdf). Additionally, the FTC has responded to questions regarding endorsements. [See here for guidance.](https://www.ftc.gov/tips-advice/business-center/guidance/ftcs-endorsement-guides-what-people-are-asking) ##Monthly Statements To give users full visibility into their account activity, please send monthly statements to users using our [Statements API](https://docs.synapsefi.com/v3.2/docs/statements-intro).