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"Financial services" are verbatim not allowed by Stripe's Acceptable Use Policy. What kind of businesses are permitted to use Stripe Treasury? Which functional

"Financial services" are verbatim not allowed by Stripe's Acceptable Use Policy. What kind of businesses are permitted to use Stripe Treasury? Which functionality is specifically provided (or anticipated to be provided) by Goldman Sachs Bank? The answer is probably a credit card. Who performs KYC? Is it Stripe FTEs, Stripe contractors, or a vendor? Is it Evolve's vendor? The answer is probably a vendor. When submitting payments or transfers, does your interface provide a way to show purpose of payment when the transfer is initiated? The answer is probably no. Not sure why this keeps getting downvoted, these are not very opinionated or critical questions. It's also pretty reasonable to just guess answers, especially benign answers, based on their competitors, if they choose not to answer. They're all good faith questions.

toomuchtodo 6y ago
This is a bit harsh. Stripe's value add is handing you an API and doing all of the hard work behind the scenes, same as Twilio (integrating with far flung telco gateways with byzantine interfaces). It's not necessary for Stripe to handle payment flows or issue cards themselves. Success is if customers are willing to pay Stripe instead of wrangling all of those vendors together themselves (which sounds like a good bet to make). Disclosure: Stripe CC processing customer, no other relation.
- senko 6y ago
  I'm not reading it as criticism. Considering Stripe forbids financial services in their t&c's, and this allows Stripe users to implement financial services, the question is, what kind of financial services are now allowed? Would be great to hear a few use cases for Treasury that can't be done with existing Connect platform (and which fall within t&c's). Genuinely curious.
  - patio11 6y ago
    Suppose a driver for a rideshare app wants to pay their car payment. Stripe Connect can't be used to hold funds from many rides for a month; they have to pay it out to a bank account (which they might not have) or to a disbursement card, which (because loan repayments are generally not paid on a card in the U.S.) likely doesn't solve their problem without withdrawing cash and buying a money order. That is extra effort and cost for the driver. Stripe Treasury would let the rideshare platform give their drivers an embedded money management account. That would allow indefinitely holding money, and would allow them to use e.g. bill pay for car payments, similar to the way that many HNers probably pay their own car payments today. This is good for the platform (solves a pain point for many drivers) and good for the drivers (they get faster access to their funds, decreasing the likelihood they'll get dinged for a late repayment, and can spend less of their time managing low-value-added money movement when they could instead be driving).
    - bavell 6y ago
      Wouldn't it be way easier and better for the driver to just open a bank account? Why would they want to tie something as important as making car payments to their ephemeral gig work?
      - closeparen 6y ago
        Many people don’t want or cannot get real bank accounts, e.g. because they can’t sustain the minimum balance, have been blacklisted for bouncing checks, or it just isn’t the norm in their community.
        lambda_obrien 6y ago
        It's kind of a slippery slope to start letting employers hold pay in an account they control... reminds me of the union busting articles on the top right now, with Facebook building employee housing now, the idea you brought up is the next step towards the "Facebook Store" and scrips. I understand some people have trouble banking, but the answer should then be for us to ensure they can have equal access to banking, no matter what.
        closeparen 6y ago
        Agreed. But this is not some gig economy thing... when an institution needs to pay you and you don't have direct deposit, often they will send you a prepaid debit card instead of a check. Even the federal government does this [0]. These cards tend to have predatory fees. [0] https://www.irs.gov/newsroom/economic-impact-payments-being-sent-by-prepaid-debit-cards-arrive-in-plain-envelope-irsgov-answers-frequently-asked-questions https://www.irs.gov/newsroom/economic-impact-payments-being-...
        lambda_obrien 6y ago
        I'm aware of that practice, and that's why I would hope that we could build something like the often talked about USPS bank, or whatever, so everyone can have equal access to real banking with no predatory practices. Not that any gig companies are doing this yet, or even thought to do it, but I just don't like the idea of this being done in a "company scrips"-like fashion, there are some things that should be totally nuclear to the touch, and tying even more of your life to your company (in the USA you have medical, housing, food, etc. tied to your work) should be nuclear.
patio11 6y ago
Stripe Treasury does not violate our terms, and allows SaaS platforms (and similar) to provide their business users with access to capabilities which are regulated with those capabilities fulfilled by entities with the appropriate licensing and backed by our financial partners. This is similar to how our Connect product lets our regulated entity do money transmission on behalf of a demand economy company without them needing to do money transmission themselves. Goldman Sachs is one of our financial partners for Stripe Treasury. Specifically, they provide custodial services for the money management accounts. For more details on this sort of thing, I'd recommend reading or having your lawyer read the contracts. KYC goes through Stripe's processes. This is both operationally complicated and something that we generally do not go into detail on. Given that the implementing SaaS business will control the UX around initiating a payment, they could control how much or little bookkeeping to do at time of a payment or transfer. Let me know if that doesn't answer the thrust of this question.
- an_opabinia 6y ago
  > Stripe Treasury does not violate our terms... Would AngelList's angel investing product, built on Treasury, violate Stripe's AUP? How about TransferWise? These are financial services companies, they are something I can imagine building on Stripe Treasury. But they are probably against your AUP, even if of course they are permissible from a legal point of view. > KYC goes through Stripe's processes. This is both operationally complicated and something that we generally do not go into detail on. One of the things I like about banks is, when you're dealing with large amounts of money, which is what I aspire to do, you are talking with an educated person on the other end of the line. It's very easy to talk with integrity because the bank's FTE is experienced, vested in a positive outcome for you, doesn't get tripped up with keywords, and critically, because they live here and are paid well, they have something at stake, you can achieve a remedy if you don't get what you need from them. With a contractor, there's a script. It's hard to talk with integrity because you might say a forbidden word, or you might merely delay your legitimate business even further by having to wait even longer for a Zendesk follow-up, or you might be dealing with someone in a foreign country beyond the law who is just going to criminally misuse information in your docs, like your passport, because SOC 2 and ISO 27001 are just policies, they're not laws and they're especially not enforcement. This is pretty consistent with everyone’s experience with contractors versus W2 in customer service and other cost departments, it is not a controversial position, it is definitely correlated with the fact that it is capricious, with no remedies, when you are locked out of eg your Google account, compared to say getting your checking account closed at a bank for non-legal reasons - at least the bank gives you the money in the account, while Google generally does not give you your emails nor responds to your support tickets. It's one thing when it's a $100 merchant payment. Who cares. It's another when it's a $1,000,000 transfer. I understand the desire to scale and compartmentalize, to use vendors. It is pretty clear that the bulk of compliance work is not done through W2 Stripe employees, although I don't see why that is possible with a bank and not with Stripe. > Given that the implementing SaaS business will control the UX around initiating a payment, they could control how much or little bookkeeping to do at time of a payment or transfer. I'm asking, how do the typical statement-of-purpose and other KYC processes adopted by other fintech firms fit into your API? For example, if my business or I transfer $1,000,000, most fintech firms ask a day or two later to fulfill more detailed statement of purpose asks, as part of a "large transfer compliance" department sort of thing, like providing an invoice and information about the recipient. I understand this is above-and-beyond any regulatory requirements but I could be wrong. So suppose my end user makes a $1,000,000 transfer that I fulfill using Stripe Treasury-backed API, do you then follow up days later with the Treasury implementer (me), via e-mail, to obtain PDFs from the end user, etc.? Or do you simply not perform this sort of above-and-beyond ask? The broader question was really about, how do you anticipate doing this KYC in an API-driven way? Or is the answer you will not? I'm not asking the specifics of the policy, I understand you cannot disclose the policy, I'm asking from a UX point of view, how will that policy be acted out? Because building the whole API implementation and then winding up in an e-mailing PDF back-and-forth with a contract Stripe employee anyway sounds pretty crummy. Are the unusual asks are part of determining whether or not the implementor / intermediary is obeying an AUP, not to fulfill legal obligations? AUPs are at once quite subjective and opinionated but also surprisingly uniform among Internet money companies, leading me to believe that this is not something anyone actually feels strongly about but really just cargo-cults. While I do not personally believe this, the most cynical belief is that this is data gathering and lead generation, that Treasury is really a Robinhood-style business, so the docs asked are retained to be later analyzed for secular, non-compliance reasons like identifying new customers (i.e., the recipients's business) and pricing.
Kye 6y ago
The nice thing about being Stripe is they can decide what the terms are. I'm sure they thought this through.

toomuchtodo 6y ago

This is a bit harsh. Stripe's value add is handing you an API and doing all of the hard work behind the scenes, same as Twilio (integrating with far flung telco gateways with byzantine interfaces). It's not necessary for Stripe to handle payment flows or issue cards themselves. Success is if customers are willing to pay Stripe instead of wrangling all of those vendors together themselves (which sounds like a good bet to make). Disclosure: Stripe CC processing customer, no other relation.

senko 6y ago
I'm not reading it as criticism. Considering Stripe forbids financial services in their t&c's, and this allows Stripe users to implement financial services, the question is, what kind of financial services are now allowed? Would be great to hear a few use cases for Treasury that can't be done with existing Connect platform (and which fall within t&c's). Genuinely curious.
- patio11 6y ago
  Suppose a driver for a rideshare app wants to pay their car payment. Stripe Connect can't be used to hold funds from many rides for a month; they have to pay it out to a bank account (which they might not have) or to a disbursement card, which (because loan repayments are generally not paid on a card in the U.S.) likely doesn't solve their problem without withdrawing cash and buying a money order. That is extra effort and cost for the driver. Stripe Treasury would let the rideshare platform give their drivers an embedded money management account. That would allow indefinitely holding money, and would allow them to use e.g. bill pay for car payments, similar to the way that many HNers probably pay their own car payments today. This is good for the platform (solves a pain point for many drivers) and good for the drivers (they get faster access to their funds, decreasing the likelihood they'll get dinged for a late repayment, and can spend less of their time managing low-value-added money movement when they could instead be driving).
  - bavell 6y ago
    Wouldn't it be way easier and better for the driver to just open a bank account? Why would they want to tie something as important as making car payments to their ephemeral gig work?
    - closeparen 6y ago
      Many people don’t want or cannot get real bank accounts, e.g. because they can’t sustain the minimum balance, have been blacklisted for bouncing checks, or it just isn’t the norm in their community.
      - lambda_obrien 6y ago
        It's kind of a slippery slope to start letting employers hold pay in an account they control... reminds me of the union busting articles on the top right now, with Facebook building employee housing now, the idea you brought up is the next step towards the "Facebook Store" and scrips. I understand some people have trouble banking, but the answer should then be for us to ensure they can have equal access to banking, no matter what.
        closeparen 6y ago
        Agreed. But this is not some gig economy thing... when an institution needs to pay you and you don't have direct deposit, often they will send you a prepaid debit card instead of a check. Even the federal government does this [0]. These cards tend to have predatory fees. [0] https://www.irs.gov/newsroom/economic-impact-payments-being-sent-by-prepaid-debit-cards-arrive-in-plain-envelope-irsgov-answers-frequently-asked-questions https://www.irs.gov/newsroom/economic-impact-payments-being-...
        lambda_obrien 6y ago
        I'm aware of that practice, and that's why I would hope that we could build something like the often talked about USPS bank, or whatever, so everyone can have equal access to real banking with no predatory practices. Not that any gig companies are doing this yet, or even thought to do it, but I just don't like the idea of this being done in a "company scrips"-like fashion, there are some things that should be totally nuclear to the touch, and tying even more of your life to your company (in the USA you have medical, housing, food, etc. tied to your work) should be nuclear.

patio11 6y ago

Stripe Treasury does not violate our terms, and allows SaaS platforms (and similar) to provide their business users with access to capabilities which are regulated with those capabilities fulfilled by entities with the appropriate licensing and backed by our financial partners. This is similar to how our Connect product lets our regulated entity do money transmission on behalf of a demand economy company without them needing to do money transmission themselves. Goldman Sachs is one of our financial partners for Stripe Treasury. Specifically, they provide custodial services for the money management accounts. For more details on this sort of thing, I'd recommend reading or having your lawyer read the contracts. KYC goes through Stripe's processes. This is both operationally complicated and something that we generally do not go into detail on. Given that the implementing SaaS business will control the UX around initiating a payment, they could control how much or little bookkeeping to do at time of a payment or transfer. Let me know if that doesn't answer the thrust of this question.

an_opabinia 6y ago
> Stripe Treasury does not violate our terms... Would AngelList's angel investing product, built on Treasury, violate Stripe's AUP? How about TransferWise? These are financial services companies, they are something I can imagine building on Stripe Treasury. But they are probably against your AUP, even if of course they are permissible from a legal point of view. > KYC goes through Stripe's processes. This is both operationally complicated and something that we generally do not go into detail on. One of the things I like about banks is, when you're dealing with large amounts of money, which is what I aspire to do, you are talking with an educated person on the other end of the line. It's very easy to talk with integrity because the bank's FTE is experienced, vested in a positive outcome for you, doesn't get tripped up with keywords, and critically, because they live here and are paid well, they have something at stake, you can achieve a remedy if you don't get what you need from them. With a contractor, there's a script. It's hard to talk with integrity because you might say a forbidden word, or you might merely delay your legitimate business even further by having to wait even longer for a Zendesk follow-up, or you might be dealing with someone in a foreign country beyond the law who is just going to criminally misuse information in your docs, like your passport, because SOC 2 and ISO 27001 are just policies, they're not laws and they're especially not enforcement. This is pretty consistent with everyone’s experience with contractors versus W2 in customer service and other cost departments, it is not a controversial position, it is definitely correlated with the fact that it is capricious, with no remedies, when you are locked out of eg your Google account, compared to say getting your checking account closed at a bank for non-legal reasons - at least the bank gives you the money in the account, while Google generally does not give you your emails nor responds to your support tickets. It's one thing when it's a $100 merchant payment. Who cares. It's another when it's a $1,000,000 transfer. I understand the desire to scale and compartmentalize, to use vendors. It is pretty clear that the bulk of compliance work is not done through W2 Stripe employees, although I don't see why that is possible with a bank and not with Stripe. > Given that the implementing SaaS business will control the UX around initiating a payment, they could control how much or little bookkeeping to do at time of a payment or transfer. I'm asking, how do the typical statement-of-purpose and other KYC processes adopted by other fintech firms fit into your API? For example, if my business or I transfer $1,000,000, most fintech firms ask a day or two later to fulfill more detailed statement of purpose asks, as part of a "large transfer compliance" department sort of thing, like providing an invoice and information about the recipient. I understand this is above-and-beyond any regulatory requirements but I could be wrong. So suppose my end user makes a $1,000,000 transfer that I fulfill using Stripe Treasury-backed API, do you then follow up days later with the Treasury implementer (me), via e-mail, to obtain PDFs from the end user, etc.? Or do you simply not perform this sort of above-and-beyond ask? The broader question was really about, how do you anticipate doing this KYC in an API-driven way? Or is the answer you will not? I'm not asking the specifics of the policy, I understand you cannot disclose the policy, I'm asking from a UX point of view, how will that policy be acted out? Because building the whole API implementation and then winding up in an e-mailing PDF back-and-forth with a contract Stripe employee anyway sounds pretty crummy. Are the unusual asks are part of determining whether or not the implementor / intermediary is obeying an AUP, not to fulfill legal obligations? AUPs are at once quite subjective and opinionated but also surprisingly uniform among Internet money companies, leading me to believe that this is not something anyone actually feels strongly about but really just cargo-cults. While I do not personally believe this, the most cynical belief is that this is data gathering and lead generation, that Treasury is really a Robinhood-style business, so the docs asked are retained to be later analyzed for secular, non-compliance reasons like identifying new customers (i.e., the recipients's business) and pricing.

Kye 6y ago

The nice thing about being Stripe is they can decide what the terms are. I'm sure they thought this through.