Customer Information Files
You will collect and verify information about your customers. You must share that information with us. To do so, you will create an
Note that if you are opening bank titled for benefit of (FBO) accounts, those accounts should be owned by one Entity in the name and tax identification number of one of our bank partners. The Entity you create for your end customer will not own any accounts.
As part of your compliance program, you’ll monitor transactions for signs of money laundering, terrorist financing, and other illicit financial activity. As you are monitoring transactions and reviewing customer identification documents, you may come across unusual activity. When you do, you must review it, validate that it is not expected behavior, and submit the details to firstname.lastname@example.org.
We’ll acknowledge we’ve received your email but we won’t provide feedback or follow up unless we need help. This is a Bank Secrecy Act / Anti-Money Laundering requirement.
You will need to maintain a ledger to track and reconcile funds belonging to each end user. You can use Increase, your own in-house technology or a third party to maintain the ledger. If you’re not using Increase we’ll ask you submit the results at the end of each day through our Bookkeeping API.
If you anticipate originating ACH debits, we will work with you to establish and maintain a Reserve Account.
Standard periodic program review
- Annually, we will review your refreshed documents and any changes to your policies or procedures.
- Annually, we will review your website, terms & conditions and fees.
- Quarterly, we will discuss program updates and new risks with your Chief Compliance Officer.
- We will periodically audit your identity verification procedures as needed.
- We will periodically request audited financial statements, if applicable.
- If you receive any notice or criticism from a regulatory authority, you should alert Increase at email@example.com and send a copy of the communication within 3 business days of receiving the complaint.
Additional requirements for consumer businesses
Marketing material review
We will review any initial marketing materials that reference the bank and/or payment services. We will work with you on proper guidelines for language used in future marketing materials. Any significant changes to your marketing materials may require additional review.
You will be responsible for providing customer service related to your program. You should establish and maintain a toll free number, and disclose this number in your terms and conditions.
You will perform quality monitoring of your customer service functions. We may periodically conduct call monitoring to assess your customer service quality.
In accordance to your Complaints Management Policy, you will track complaints and handle resolutions. You will share a monthly report of your complaints tracking with Increase.