Platform implementation guide
If you’re moving your customer’s money, you likely already know about some of the compliance requirements. This guide addresses how to implement a few of these requirements.
This guide covers customer onboarding: collecting your customers’ information and setting up their accounts. If you use Increase directly for your own business and don’t serve end customers, see Compliance programs for what applies to you.
You’ll need to:
- Know whose money you’re moving.
- Keep track of what money belongs to each of your customers.
- Share these details with us.
Setting up your Accounts correctly makes this much easier. First you’ll need to determine what Account structure is right for you and who will legally own the Accounts.
Account structure
Typically we recommend spinning up an individual Account for each of your customers. This prevents the need to keep a separate ledger. It also gives you maximum flexibility for Account ownership. Account creation is synchronous. There is no limit on the number of Accounts you can create.
Alternatively you can have one commingled Account. You’ll need to keep track of whose funds are whose. In either structure, you can also create unique Account Numbers. These are particularly useful for tracking inbound payments. Account Number creation is also synchronous. There is no limit on the number of Account Numbers you can create.
Account ownership
Every Account is owned by an Entity. When moving money on behalf of customers, there are three common options:
- Option 1: Entities are created for individual customers, each of which owns their own Account.
- Option 2: Accounts are owned by the bank’s Entity for the benefit (FBO) of your customers. The beneficiary of the funds is also tagged to the Account.
- Option 3: Accounts are owned by your own Entity. The beneficiary of the funds is also tagged to the Account.
In order for you to own the Account, option 3, you’ll need to ensure you have the appropriate regulatory permissions. You’ll definitely want to chat with your legal team on this.
In some scenarios, it’s not possible to have a separate Account for each of your customers. In that case, you can create “commingled” Accounts. It’s best to avoid this, so we recommend chatting through this with support@increase.com.
Who are your customers
Your bank partner keeps track of your customers using the information you provide about each of them. Regardless of the legal Account owners, we’ll need all of the required information for each of your customers. Each time you onboard a new customer, you’ll create a new Entity in Increase.
Funds in Increase belong to exactly one Account. Each Account can have two Entities associated with it, stored as pointers named entity_id and informational_entity_id.
| Account Ownership | Implementation |
|---|---|
| Individual customers own Accounts | Each Account’s entity_id will be an Entity identifying your customer. There is no informational_entity_id in this situation. |
| Accounts are owned by the bank for the benefit (FBO) of your customers | Each Account’s entity_id will be an Entity identifying the bank partner. Each Account’s informational_entity_id will be an Entity for your customer who is the beneficiary of the funds. |
| You own accounts | Each Account’s entity_id will be your corporate entity. Each Account’s informational_entity_id will be an entity for your customer who is the beneficiary of the funds. |
Customer information and identity verification
You’re responsible for collecting the required information about each of your customers and providing it to Increase. You can create Entities yourself through the Entity API or in the dashboard. Alternatively, you can have Increase collect the information from your customers through Hosted onboarding.
Depending on your compliance model, identity verification may be performed by your own compliance program or as part of a managed compliance process. In either case, design your integration and onboarding experience so it can handle follow-up requests for additional information when needed.
To share verification evidence or supporting documentation, attach files using the supplemental_documents parameter on Entity creation. Pass the ids of one or more Files created via the File API. These can be unstructured content. For example, a PDF of an identity document or a JSON blob returned by a verification provider.
Tracking customer balances
We’ll keep track of how much money each of your customers is holding. We recommend tracking by creating individual customer Accounts with no funds commingled across multiple customers. Your customers’ balances stay in sync with their payment activity in Increase. If you use a commingled structure, you’ll need to maintain your own ledger to reconcile the funds belonging to each end user.
Reserve Account
If you anticipate originating ACH debits, your bank partner will work with you to establish and maintain a Reserve Account.
Marketing material review
Your bank partner will review any initial marketing materials that reference the bank and/or payment services. Your bank partner 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.
Consumer Program requirements
If your Program serves consumers, the following additional requirements apply, regardless of your compliance model:
Customer service
You will be responsible for providing customer service related to your Program. Your bank partner will perform quality monitoring of your customer service functions.
Complaints tracking
In accordance with your Complaints Management Policy, you will track complaints and handle resolutions. You will share a monthly report of your complaints tracking with your bank partner.
If you have any questions don’t hesitate to reach out to support@increase.com.