{"_id":"5bd2604f383483000db6cf58","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":"5bce6a3580a7250031199f34","project":"59f79e3c584eb200345ceafc","version":"5ba178b00a916500030c6a21","__v":0,"sync":{"url":"","isSync":false},"reference":false,"createdAt":"2018-10-23T00:24:21.671Z","from_sync":false,"order":18,"slug":"card-number-issuance","title":"Issue Debit Card"},"user":"5bbfeeea7f922a0003f04c65","__v":0,"parentDoc":null,"updates":[],"next":{"pages":[],"description":""},"createdAt":"2018-10-26T00:31:11.227Z","link_external":false,"link_url":"","sync_unique":"","hidden":false,"api":{"results":{"codes":[]},"settings":"","auth":"required","params":[],"url":""},"isReference":false,"order":9,"body":"A consumer debit card is a payment card that can be used when making purchases, the funds are debited directly from the user’s deposit account when performing a transaction. It can be a physical or virtual card. Debit cards are not an extension of credit and purchases are debited directly from the user’s deposit accounts, they should be marketed in a manner true to the capabilities of the product. \n \n##Disclosure Requirements\nIn addition to the CFPB UDAAP requirements, SynapseFI will require the Platform to be compliant with all requirements set forth in Regulation E (“Reg E”), and the [Electronic Fund Transfer Act](https://www.federalreserve.gov/boarddocs/supmanual/cch/efta.pdf)(“EFTA”) to the extent applicable. This Act states:\n* Disclosures must be clear and easily understood, in writing, and in a form the consumer may keep.\t\n* The disclosures may be provided via electronic form if the consumer has affirmatively consented, after receiving a notice compliant with the E-Sign Act.\n* Disclosures may be made available in a language, other than English, if they are also made available in English upon request.\n* Disclosures must be provided at the time a consumer contracts for an electronic fund transfer service or before the first electronic fund transfer is made involving the consumer's account.\n* Disclosures are required to contain the following information as it applies:\n* Liability of the user for unauthorized electronic funds transfers\n* Telephone number and address for the user to report possible fraud\n* Platform’s business days\n* Limitations on frequency or dollar amounts related to transfers\n* Any fee that may be imposed\n* Summary of the user’s right to receipts and periodic statements\n* Summary on the user’s right to stop payment, and the procedures for doing so\n* The liability of the Platform to the user for failure to make or stop certain transfers\n* The circumstances under which, in the course of business, the Platform may provide information related to the user’s account to third parties\n* Error resolution notice ([See Model form A-3](https://www.consumerfinance.gov/eregulations/1005-A/2013-19503#1005-A-2-i-))\n\n##Marketing Representations\nPlease note, your Platform should not reference SynapseFI or Evolve Bank & Trust in any other way without express written permission from the respective entity.\n\n##Notice of Change of Terms\nAny notice of a change of terms must be mailed or delivered to the user at least 21 days before the effective date, if it will result in:\n* Increased fees for the consumer;\n* Increased liability for the consumer;\n* Fewer types of available electronic fund transfers; or\n* Stricter limitations on the frequency or dollar amount of transfers\n\n##Upon Issuing a Card\nIf a User is opening a CARD-US Node, it will be linked to a DDA. Include a checkbox and the following verbiage on the page that the User is created:\n\t\t\t\t\t\t\n*“The bank services are provided by Evolve Bank & Trust, Member FDIC. By opening a Visa Debit Card, linked to a deposit account on <Insert Platform Name>, you agree to Evolve Bank & Trust’s Deposit Agreement and Consumer Visa Card Agreement\"\n“Deposit Agreement” and “Consumer Visa Card Agreement” shall be hyperlinks to the Platform’s custom agreements, provided by SynapseFI.*\t\n\nIf a User is opening a SUBCARD-US Node, it will be linked to an FBO deposit account. Include a checkbox and the following verbiage on the page the User is created:\n\n*\"By using our services and opening a Visa Debit Card, you agree to Evolve Bank & Trust’s Consumer Visa Card Agreement.\"*\n\n“Consumer Visa Card Agreement” shall be hyperlink to the platform’s custom agreement, provided by SynapseFI.  \t\n\nNote: Platform’s FBO account is a Fiduciary Deposit Account with Evolve Bank & Trust titled in Platform’s legal name “for benefit of” Platform’s Users. The FBO account is subject to the Deposit Account Agreement, Privacy Policy, and related agreement for Evolve Bank & Trust found here.\n\t\t\t\t\t\t\n##Legal Agreements Accessibility\nAll disclosures, agreements, and policies required for creating a user must be compiled in a central location, and easily accessed by the Users, including the Cardholder Agreement. This may be accomplished by one of the following:\nInclude 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.\nCompile all documents within a “settings”, or similar, page under the User’s profile.\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\t\t\t\t\t\n##Visa Limitations\nProposed designs for cards and accompanying mailers must be submitted for approval from Visa, CPI Card Group, and SynapseFI prior to production, and each time a change is made. \n \nPer the Visa Debit Card agreement, when marketing Consumer Visa Debit Cards, the Platform is not authorized to display Visa’s logo at any time, including visual guidance or tutorials and advertisements related to the the card. \n \n##Protecting Card Data \nPlatforms are expected to be PCI compliant if they will be accepting, transmitting, or storing any cardholder data. It is the Platform’s responsibility to determine the appropriate level of compliance for their processing or handling volume. In regards to marketing material, if the Platform will be displaying images of cards in advertisements, on websites or mobile applications, or any other communications, the Platform must list sequential or repeating numbers (1234…, 1111...), x’s, or dashes in place of card numbers and security codes to avoid potentially compromising real card data. \n \n##Disputes\nThe Platform must provide contact information for Users to submit debit card transaction disputes. This information is included in the Consumer Visa Card Agreement, but should also be listed on their contact page within their website or application, and should be easy to locate. [Learn more about disputes.](https://docs.synapsefi.com/v3.2/docs/dispute-a-transaction)","excerpt":"Legal disclosures for the debit card","slug":"legal-disclosures-9","type":"basic","title":"Legal Disclosures"}

Legal Disclosures

Legal disclosures for the debit card

A consumer debit card is a payment card that can be used when making purchases, the funds are debited directly from the user’s deposit account when performing a transaction. It can be a physical or virtual card. Debit cards are not an extension of credit and purchases are debited directly from the user’s deposit accounts, they should be marketed in a manner true to the capabilities of the product. ##Disclosure Requirements In addition to the CFPB UDAAP requirements, SynapseFI will require the Platform to be compliant with all requirements set forth in Regulation E (“Reg E”), and the [Electronic Fund Transfer Act](https://www.federalreserve.gov/boarddocs/supmanual/cch/efta.pdf)(“EFTA”) to the extent applicable. This Act states: * Disclosures must be clear and easily understood, in writing, and in a form the consumer may keep. * The disclosures may be provided via electronic form if the consumer has affirmatively consented, after receiving a notice compliant with the E-Sign Act. * Disclosures may be made available in a language, other than English, if they are also made available in English upon request. * Disclosures must be provided at the time a consumer contracts for an electronic fund transfer service or before the first electronic fund transfer is made involving the consumer's account. * Disclosures are required to contain the following information as it applies: * Liability of the user for unauthorized electronic funds transfers * Telephone number and address for the user to report possible fraud * Platform’s business days * Limitations on frequency or dollar amounts related to transfers * Any fee that may be imposed * Summary of the user’s right to receipts and periodic statements * Summary on the user’s right to stop payment, and the procedures for doing so * The liability of the Platform to the user for failure to make or stop certain transfers * The circumstances under which, in the course of business, the Platform may provide information related to the user’s account to third parties * Error resolution notice ([See Model form A-3](https://www.consumerfinance.gov/eregulations/1005-A/2013-19503#1005-A-2-i-)) ##Marketing Representations Please note, your Platform should not reference SynapseFI or Evolve Bank & Trust in any other way without express written permission from the respective entity. ##Notice of Change of Terms Any notice of a change of terms must be mailed or delivered to the user at least 21 days before the effective date, if it will result in: * Increased fees for the consumer; * Increased liability for the consumer; * Fewer types of available electronic fund transfers; or * Stricter limitations on the frequency or dollar amount of transfers ##Upon Issuing a Card If a User is opening a CARD-US Node, it will be linked to a DDA. Include a checkbox and the following verbiage on the page that the User is created: *“The bank services are provided by Evolve Bank & Trust, Member FDIC. By opening a Visa Debit Card, linked to a deposit account on <Insert Platform Name>, you agree to Evolve Bank & Trust’s Deposit Agreement and Consumer Visa Card Agreement" “Deposit Agreement” and “Consumer Visa Card Agreement” shall be hyperlinks to the Platform’s custom agreements, provided by SynapseFI.* If a User is opening a SUBCARD-US Node, it will be linked to an FBO deposit account. Include a checkbox and the following verbiage on the page the User is created: *"By using our services and opening a Visa Debit Card, you agree to Evolve Bank & Trust’s Consumer Visa Card Agreement."* “Consumer Visa Card Agreement” shall be hyperlink to the platform’s custom agreement, provided by SynapseFI. Note: Platform’s FBO account is a Fiduciary Deposit Account with Evolve Bank & Trust titled in Platform’s legal name “for benefit of” Platform’s Users. The FBO account is subject to the Deposit Account Agreement, Privacy Policy, and related agreement for Evolve Bank & Trust found here. ##Legal Agreements Accessibility All disclosures, agreements, and policies required for creating a user must be compiled in a central location, and easily accessed by the Users, including the Cardholder Agreement. 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. ##Visa Limitations Proposed designs for cards and accompanying mailers must be submitted for approval from Visa, CPI Card Group, and SynapseFI prior to production, and each time a change is made. Per the Visa Debit Card agreement, when marketing Consumer Visa Debit Cards, the Platform is not authorized to display Visa’s logo at any time, including visual guidance or tutorials and advertisements related to the the card. ##Protecting Card Data Platforms are expected to be PCI compliant if they will be accepting, transmitting, or storing any cardholder data. It is the Platform’s responsibility to determine the appropriate level of compliance for their processing or handling volume. In regards to marketing material, if the Platform will be displaying images of cards in advertisements, on websites or mobile applications, or any other communications, the Platform must list sequential or repeating numbers (1234…, 1111...), x’s, or dashes in place of card numbers and security codes to avoid potentially compromising real card data. ##Disputes The Platform must provide contact information for Users to submit debit card transaction disputes. This information is included in the Consumer Visa Card Agreement, but should also be listed on their contact page within their website or application, and should be easy to locate. [Learn more about disputes.](https://docs.synapsefi.com/v3.2/docs/dispute-a-transaction)