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Any company that has a relationship with a bank that holds money for consumers has to clear every single email template (any customer communication) with the ba

Any company that has a relationship with a bank that holds money for consumers has to clear every single email template (any customer communication) with the bank before being sent to customers. So, netspend for instance has to clear any content with their bank previous to sending it to customers. This incident likely caused numerous TOS and regulatory violations which open up all of those financial service providers to fines from the CFPB, and perhaps law suits from customers.

ajcp 6y ago
I'm not sure that is correct in this case. It appears Netspend was interacting with their own customer in the context of one of it's own processes. They weren't doing so as a TPV working on behalf of the banking institution that the customer would be using Netspend to transfer money from/to. -Example- Netspend: Thanks for signing up for Netspend. We need to verifying your real. Please go to netspend.com/validate and provide y. If Netspend was asking or directing the customer to provide information on, or interact with the banking institutions own properties then yes, I can see how you'd be correct. -Example- Netspend: You've indicated you use Example Bank. In order for us to link to your EB account please go to example.com/myaccount and do x, y, and z.
tootie 6y ago
They don't technically have to. Responsible banks will carry out risk and compliance audits of all customer communication to avoid liability but the alternative is to publish whatever and then deal with lawsuits later. These audits typically only for "claims" language (ie "we offer the lowest rates" would be axed) and maybe accessibility but not technical QA.
- datavirtue 6y ago
  I was referring to the prepaid companies like netspend mostly. In my experience every bank required this of each of the prepaid companies I was at. At one prepaid company we went through three banks. The business is considered high risk...for very good reason.

ajcp 6y ago

I'm not sure that is correct in this case. It appears Netspend was interacting with their own customer in the context of one of it's own processes. They weren't doing so as a TPV working on behalf of the banking institution that the customer would be using Netspend to transfer money from/to. -Example- Netspend: Thanks for signing up for Netspend. We need to verifying your real. Please go to netspend.com/validate and provide y. If Netspend was asking or directing the customer to provide information on, or interact with the banking institutions own properties then yes, I can see how you'd be correct. -Example- Netspend: You've indicated you use Example Bank. In order for us to link to your EB account please go to example.com/myaccount and do x, y, and z.

tootie 6y ago

They don't technically have to. Responsible banks will carry out risk and compliance audits of all customer communication to avoid liability but the alternative is to publish whatever and then deal with lawsuits later. These audits typically only for "claims" language (ie "we offer the lowest rates" would be axed) and maybe accessibility but not technical QA.

datavirtue 6y ago
I was referring to the prepaid companies like netspend mostly. In my experience every bank required this of each of the prepaid companies I was at. At one prepaid company we went through three banks. The business is considered high risk...for very good reason.