Milestone 1: TabaPay Review

Set up all your requirements.

Your TabaPay sales representative will send a kick off email inviting you to submit a merchant application, agreement, and supplementary material. The application will collect information about your business, any UBOs, and its authorized signers. The supplementary material will consist of business documentation, policies, financial history, and other items TabaPay may choose to request based on use case and merchant type, as described below.

Minimum requirements for acquiring Sponsorship

To qualify, your company at a minimum:

  1. Provides complete and proper corporate and financial documentation as listed by TabaPay's Compliance team during onboarding
  2. Has a functioning website that displays Terms and Conditions to the cardholder
  3. Is not subject to any administrative or regulatory enforcement action, pending or threatened class action lawsuits
  4. Does not have any control person or ultimate beneficial owner (UBO) on any sanctions, watch, or Politically Exposed Persons (PEP) lists
  5. Has never before been kicked off a payment network for violating network standards or rules
  6. Can meet financial obligations related to settlement exposure and potential liabilities resulting from adverse events such as chargebacks, fines, or reversals
  7. Is properly licensed for all applicable activity and in all applicable jurisdictions for business that it conducts (e.g. money transmission, lending, brokerage)
  8. Has a compliance program in place specific to its business model and use case addressing regulatory and compliance obligations
  9. Has controls in place to mitigate fraud, money laundering, or terrorist financing commensurate with the company's type, size, and use case.

Please reach out to your sales representative or [email protected] if you have any questions or concerns regarding your use case, merchant category, and related requirements.

Common Use Cases and Compliance Requirements

Use Case Description Supporting Compliance Documents
Consumer Cash Advances Disbursement or collection of micro-credit product that does not apply a financing charge KYC and OFAC policy or process description
Early Wage Advances Disbursement or collection of micro-credit product that does not apply a financing charge KYC and OFAC policy or process description

Prohibited Business List
Lending Disbursement or collection of regulated credit product by Licensed Lender or Financial Institution Lender Attestation
disbursements only: demonstration of Visa & MC's fair lending guidelines

KYC and OFAC policy or process description

UDAAP and Collections Policy

Evidence of Licenses
Person-to-person

Pulling funds from or disbursing funds to cardholders/account holders for domestic or cross border person-to-person money remittance conducted by a licensed entity
Merchants that facilitate person-to-person transactions are either licensed (MCC 4829) or rely on license of an FDIC or NCUA member financial institution in good standing (MCC 6012) BSA/AML/OFAC and Transaction Monitoring Policies

AML Audit & Management Response

Evidence of Licenses
Account-to-Account (i.e. account funding or offloading) Limited Agent, Program Manager, or Banking-as-a-Service Provider enabling Bank-sponsored financial services that wants to enable loading or offloading funds from or to an external account

Merchants that facilitate banking-services are either licensed (MCC 4829) or rely on license of an FDIC or NCUA member financial institution in good standing (MCC 6012)
BSA/AML/OFAC and Transaction Monitoring Policies

AML Audit & Management Response

Evidence of Licenses
Business-to-Business payments

Accepting payments from businesses or sending payments to vendor
Business-to-Business Payment Provider that wants to enable invoice payments BSA/AML/OFAC and Transaction Monitoring Policies

AML Audit & Management Response

Legal Opinion or Evidence of Licenses
Consumer Bill Payments

Accepting payments from consumers on behalf of businesses or sending payments to businesses on behalf of consumers
Consumer Bill Payment Provider that wants to enable utilities or other consumer bill payments BSA/AML/OFAC and Transaction Monitoring Policies

AML Audit & Management Response

Legal Opinion or Evidence of Licenses
Aggregators

Merchant that enable a single use case as described throughout this exhibit on behalf of sub-merchants
Software-as-a-Service platforms specialized within a single business vertical Know-Your-Business Policy

Additional requirements by use cases and determined by TabaPay Compliance and Sponsor Bank
Sub-merchant Settlement or Gig Worker Payouts Marketplaces or eCommerce platforms that enable businesses, micro-merchants, or gig workers to market their services and accept payment through their platform BSA/AML/OFAC and Transaction Monitoring Policies

AML Audit & Management Response

Legal Opinion or Evidence of Licenses
Accepting or making payments for high-risk use cases, such as crypto or high-risk security brokerages High Risk Merchants (HRM) must undergo Visa and Mastercard enhanced reviews and be registered with each network BSA/AML/OFAC and Transaction Monitoring Policies

AML Audit & Management Response

Legal Opinions per State

Evidence of Licenses

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(1) Evidence of Licensing

Some platforms enabling regulated banking or financial activities (e.g. challenger banks, limited agents or program managers) partner with an FDIC or NCUA member Financial Institution (FI) rather than become licensed themselves. If this describes your business model, there are two considerations:

  1. We collect a letter affirming the relationship between you and your bank. TabaPay calls it an Agency Letter as limited agency is the most common type of engagement to an FI.

We will provide a template of that letter to give to your FI which can be amended as needed so long as it establishes:

  • The financial services you offer are sanctioned and overseen by your partnering FI
  • Your company is not receiving funds resulting from the activity TabaPay is facilitating; the funds remain under the control of the FI and the individual users of your program.
  • Your FI is aware of TabaPay's involvement in the transaction flow
  • TabaPay will be notified should the relationship between you and your FI end.

The letter should be signed by an authorized representative of the FI's legal or compliance department.

  1. Your partnering FI should be clearly disclosed to your users as the purveyor of banking and financial services on your marketing material and in the terms and conditions with your users.

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(2) Know Your Business ("KYB") process

A Trevi Pay Survey of 150 businesses in 2021 found the 98% of businesses "experienced financial losses (averaging 3.5% of a B2B business’s annual revenue) due to successful fraud attacks last year."

Any one of our customers that boards a company as a client on our system is required to have validated the company's existence and good standing and the individuals representing the business as signers to any application or agreement. Please see here for more detail