{"_id":"5bc1235c938ccd0003356624","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":"5ba2dcbc99f53f0003b97e2c","project":"59f79e3c584eb200345ceafc","version":"5ba178b00a916500030c6a21","__v":0,"sync":{"url":"","isSync":false},"reference":false,"createdAt":"2018-09-19T23:33:16.071Z","from_sync":false,"order":8,"slug":"deposit-accounts","title":"Deposit Accounts"},"user":"5bbfeeea7f922a0003f04c65","__v":0,"parentDoc":null,"updates":[],"next":{"pages":[],"description":""},"createdAt":"2018-10-12T22:42:36.409Z","link_external":false,"link_url":"","sync_unique":"","hidden":false,"api":{"results":{"codes":[]},"settings":"","auth":"required","params":[],"url":""},"isReference":false,"order":5,"body":"An individual non-interest bearing DDA allows the depositor to withdraw their funds from the account without warning or with less than seven days' notice. This is a transactional account which does not accrue interest, and should be marketed as such. \n \n##Marketing Representations\nMarketing of non interest bearing demand 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. Additionally, the Platform will not reference SynapseFI or our partner bank in any other way without express written permission from the respective entity.\n\nThe Platform will not misrepresent their relationship to SynapseFI or our partner bank, nor will they claim a direct relationship with our partner bank. To explain the association, disclosures will include language similar to:\n\n*“The Platform partners with SynapseFI, our third-party bank software provider and agent of Evolve Bank & Trust, Member FDIC, to open these accounts.”*\n\n##Upon Opening a Deposit Account\nIf a User is opening a DEPOSIT-US Node, they must accept the User Deposit Agreement, with the following verbiage on the page the account 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\n“Deposit Agreement” shall be a hyperlink to the Platform’s custom Deposit Agreement, provided by SynapseFI. \n\n\t\n##Contact Information\nPlatform should include our contact information on their customer support page.\n\n*\"Bank services are provided through our banking software provider, SynapseFI. To report a complaint related to bank services, email help:::at:::synapsefi.com.\"*\n\n##Truth In Savings Disclosures\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\nIf platform intends to provide users with financial incentives to maintain balances, on a non interest bearing account, it must be clear that the incentive is being paid by the Platform. The following terms cannot be used:\n* Interest\n* Yield\n* Annual Percentage Rate (“APR”)\n* Annual Percentage Yield (“APY”)\n\nAs an alternative, platform may use the following:\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\n##Legal Agreements Accessibility\nAll disclosures, agreements, and policies required for creating a new 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.\n* Compile 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* 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.\n\n##FDIC Insurance\nDeposit accounts are insured through Evolve Bank & Trust. The platform will not claim to be FDIC insured directly. Account insurance coverage is subject to FDIC rules and limitations.\n\nFor all pages that reference transactions, funds held in a User’s Deposit Account, or other services covered by the Deposit Agreement, include the following in 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 Federal Trade Commission (\"FTC\") has released additional guidance, which must be adhered to. SynapseFI strongly suggests screening procedures are 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). \nAdditionally, the FTC has responded to questions regarding endorsements. [Please see additional following guidance.](https://www.ftc.gov/tips-advice/business-center/guidance/ftcs-endorsement-guides-what-people-are-asking)\n \n##Monthly Statements\nTo provide end-users with the full detail of their account activity, please send monthly statements to users with our [Statements API](https://docs.synapsefi.com/v3.2/docs/statements-intro).","excerpt":"Deposit account legal disclosures","slug":"legal-disclosures-deposit-accounts","type":"basic","title":"Legal Disclosures"}

Legal Disclosures

Deposit account legal disclosures

An individual non-interest bearing DDA allows the depositor to withdraw their funds from the account without warning or with less than seven days' notice. This is a transactional account which does not accrue interest, and should be marketed as such. ##Marketing Representations Marketing of non interest bearing demand 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. Additionally, the Platform will not reference SynapseFI or our partner bank in any other way without express written permission from the respective entity. The Platform will not misrepresent their relationship to SynapseFI or our partner bank, nor will they claim a direct relationship with our partner bank. To explain the association, disclosures will include language similar to: *“The Platform partners with SynapseFI, our third-party bank software provider and agent of Evolve Bank & Trust, Member FDIC, to open these accounts.”* ##Upon Opening a Deposit Account If a User is opening a DEPOSIT-US Node, they must accept the User Deposit Agreement, with the following verbiage on the page the account 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.”* “Deposit Agreement” shall be a hyperlink to the Platform’s custom Deposit Agreement, provided by SynapseFI. ##Contact Information Platform should include our contact information on their customer support page. *"Bank services are provided through our banking software provider, SynapseFI. To report a complaint related to bank services, email [email protected]"* ##Truth In Savings Disclosures 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 ) If platform intends to provide users with financial incentives to maintain balances, on a non interest bearing account, it must be clear that the incentive is being paid by the Platform. The following terms cannot be used: * Interest * Yield * Annual Percentage Rate (“APR”) * Annual Percentage Yield (“APY”) As an alternative, platform may use the following: * Reward * Rebate * Bonus - provided that [CFPB’s definition](https://www.consumerfinance.gov/eregulations/1030-2/2011-31727#1030-2-b-2) is met ##Legal Agreements Accessibility All disclosures, agreements, and policies required for creating a new 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 Deposit accounts are insured through Evolve Bank & Trust. The platform will not claim to be FDIC insured directly. Account insurance coverage is subject to FDIC rules and limitations. For all pages that reference transactions, funds held in a User’s Deposit Account, or other services covered by the Deposit Agreement, include the following in 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 Federal Trade Commission ("FTC") has released additional guidance, which must be adhered to. SynapseFI strongly suggests screening procedures are 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. [Please see additional following guidance.](https://www.ftc.gov/tips-advice/business-center/guidance/ftcs-endorsement-guides-what-people-are-asking) ##Monthly Statements To provide end-users with the full detail of their account activity, please send monthly statements to users with our [Statements API](https://docs.synapsefi.com/v3.2/docs/statements-intro).