Field GuideLast reviewed October 2026
Card issuing: launching a card program
How a fintech or software platform launches prepaid, debit and credit cards: who lends the licence and the BIN, how long each partner takes to say yes, why interchange and the Durbin exemption decide the economics, and who pays when the ledger or a partner fails.
The industry on one page
Picture a payroll and scheduling platform for restaurants that wants to give its customers' hourly workers a card. Wages would land on it on payday, workers could draw part of their pay early, and the platform would earn a slice of every purchase instead of charging for transfers. Before a single card ships it has to decide whose licence it borrows, whose systems answer each purchase, who keeps track of every worker's balance, and how long the partners will take to say yes.
A card payment travels from the merchant's side (the shop and its acquirer, the bank that takes card payments for it) through the card network, Visa or Mastercard, to the issuer processor, the company that holds the card records and answers authorization requests. The processor asks your program to decide: approve, decline or approve part of it, though it settles simple cases like an inactive card on its own. The sponsor bank sits behind all of this. It lends the program its licence and its BIN (bank identification number, the first six to eight digits of every card number), holds the cardholders' money and settles with the network every business day. In most programs, your program, the non-bank whose name is on the app, keeps the ledger: which worker owns how much of the money in the bank's pooled account.
The split of duties is messier than "the bank owns it". Visa's rules make the bank that holds a BIN responsible and liable for everything that happens on it, including losses its agents cause, and the bank holds the money. The ledger, though, often belongs to the program: Chime built its own processor and ledger, ChimeCore, and calls it the system of record for its members' accounts. So the bank's licence and liability sit underneath, the network's rules sit on top, and the program's ledger sits in the middle, where the bank has to be able to read it and reconcile it every day. When the two sets of books disagree, money freezes at a solvent bank, as it did for over 100,000 people when Synapse, a middleware company between fintechs and banks, collapsed in 2024.
What I'd want a new PM in this space to take away:
- The bank's rulebook: the sponsor bank approves the program, every change and every partner you bring; the network approves the card design, and the bank registers you with the network as its agent. Most "rules" arrive as the bank's policy, and a regulator's order against the bank can rewrite them overnight.
- The partners' clock: bank due diligence, network approval and custom plastic cards each take weeks to months. A custom program on its own sponsor bank takes roughly four to nine months by my estimate; stock or virtual cards through an existing card-issuing platform can take days.
- Interchange economics: for US debit and prepaid, revenue is mostly interchange (the fee the merchant's bank pays the card's bank on each purchase), and the Durbin Amendment caps it for banks with $10 billion or more in assets. In 2024 exempt banks earned about $0.51 a transaction against $0.23 at capped ones, which is why fintech sponsor banks are small and work hard to stay that way. More in Durbin and the exempt-bank model.
- The ledger: whoever keeps it, the bank has to be able to see every cardholder's balance and tie it to its own account to the cent. See System of record & ledger.
- Leaving: Chime's bank contracts run three to five years with six to twelve months' notice, disputes trail on for six months or more after a move, and the network won't release a BIN until it's been quiet for 120 days.
Corporate, purchasing and expense cards are in B2B payments: spend management. Checking cardholders' identity and the 2024 consent orders against sponsor banks are in Identity and trust. The two seconds of an authorization, clearing and settlement belong to a later guide in this series, as does credit underwriting.
The main players
These are the names behind the diagram's roles, in no particular order.
Card networks
- What they do
- Carry the payment, write the rules, license BINs
- Main players
- Visa, Mastercard, Discover (Capital One), Interac in Canada
- What they control
- Interchange tables, program and design approval, agent registration, stand-in
Sponsor and issuing banks
- What they do
- Hold the licence, the BIN and the money; settle with the network
- Main players
- The Bancorp, Pathward, Sutton Bank, Coastal Community Bank, Lead Bank; Peoples Trust in Canada
- What they control
- Which programs exist, every change to them, reserves, the interchange split, termination
Issuer processors and card-issuing platforms
- What they do
- Keep card records and answer authorizations; platforms bundle a bank
- Main players
- FIS (TSYS), Fiserv, Marqeta, Galileo (SoFi), Stripe Issuing, Adyen
- What they control
- Timeouts and fallbacks, the data you see, how hard it is to leave
Program managers and BaaS
- What they do
- Own the product and the customer; middleware connects fintechs to banks
- Main players
- Chime, Green Dot, Lithic (program management), Synctera, Treasury Prime
- What they control
- The cardholder relationship, the ledger, the brand
Card manufacturers and fulfilment
- What they do
- Make, personalize and mail the plastic
- Main players
- CPI Card Group, CompoSecure, Giesecke+Devrient
- What they control
- Lead times, minimum runs, unit cost
Token services and wallets
- What they do
- Swap the card number for a device token; put the card on the phone
- Main players
- Visa Token Service, Mastercard MDES, Apple Pay, Google Wallet, Samsung Wallet
- What they control
- Who can add a card to a phone, and what the wallet charges
How they make money, and who's moving:
- Networks charge fees on both sides of every transaction and publish interchange tables twice a year. Visa's net revenue grew 14% in its quarter to June 2026, and Mastercard's switched transactions grew 9%. Capital One moved about 25 million of its debit cards onto Discover's network by mid-2026, after buying it.
- Sponsor banks earn per-transaction and monthly fees, a slice of interchange and cheap deposits. The Bancorp's fintech fees grew by about a fifth in 2025, to about $140 million, and 91% of its deposits come from fintech partners. Pathward's card and deposit fees fell as custodial deposits shrank. Coastal's banking-as-a-service fees kept growing in mid-2026, the quarter it took a $69 million charge on one credit partner. Lead Bank and Cross River were the launch banks for Visa's USDC settlement in December 2025.
- Processors and platforms charge per transaction and per card, or keep a share of interchange. FIS closed its $13.5 billion purchase of Global Payments' issuer business (the old TSYS) in January 2026. Marqeta's volume grew by about a third to $120 billion in the quarter to June 2026, though Block was 45% of its 2025 revenue and is moving some new business elsewhere. Galileo's enabled accounts fell from 160 million to 135 million after a large client left. Adyen says its issuing customers nearly doubled in the six months to June 2025; Stripe doesn't report Issuing on its own.
- Program managers keep most of the interchange plus their own fees. Chime's debit interchange was 49% of its roughly $2.2 billion revenue in 2025. Green Dot is being split, its bank going to CommerceOne and its fintech business to Smith Ventures for $690 million, pending bank approvals. After Synapse, middleware firms like Synctera and Treasury Prime moved toward selling to banks.
- Card makers charge per card, plus personalization and mailing. CPI Card Group's revenue grew 13% in 2025 to about $540 million, helped by buying Arroweye, an on-demand card maker. CompoSecure, the metal-card maker, got almost two-thirds of its 2024 sales from JPMorgan and American Express. G+D reported flat revenue of about €3.2 billion for 2025.
- Token services and wallets: Visa says it had provisioned over 16 billion tokens by September 2025, and Mastercard says about 40% of its transactions were tokenized by late 2025. Apple charges issuers a reported 0.15% on credit and half a cent per debit purchase; Google and Samsung charge nothing, according to the US Justice Department's complaint. A class of US issuers suing Apple over those fees was certified on September 23, 2026.
As of October 2026. Players change through acquisitions, splits and migrations, so treat this as a map to check before relying on it.
Once the payroll platform launches, a sponsor bank like The Bancorp lends it an account range inside one of its Visa BINs. A processor like Marqeta holds the card records and calls the platform's servers when a cook taps the card at a grocery store. CPI Card Group prints the plastic, and Visa Token Service puts the card into Apple Pay. Visa settles with the bank every business day, the bank passes the platform its share of interchange, and the platform's ledger says which part of the bank's pooled account belongs to which cook. That's six or seven companies behind one card, and the platform signs contracts with three of them.
How a program launches, step by step
Here's the payroll platform's path from idea to a cook using the card. The partners set the pace: bank due diligence, network approval and custom card production each take weeks to months, and finished code doesn't speed any of them up. Through an existing card-issuing platform, it could issue stock or virtual cards within days, because the platform did the bank and network work once and even its wallet approvals cascade down to its customers.
- Model chosen: own BIN (you're the bank), a sponsor bank plus your own program management, or embedded issuing through a platform; and the card type, prepaid, debit, credit or commercial. I'd also decide here who holds the ledger, since it's the hardest thing to change later. Breaks: picking a bank only on its interchange, then finding it's under a regulator's order or close to $10 billion in assets.
- Bank approved: the bank signs after due diligence and a program agreement. Expect to send two years of financials, insurance, your anti-money-laundering, identity, PCI and fraud policies, a business plan and a flow of funds. One processor's guide says sponsor banks look for $3-5 million of capital raised or a large user base. Visa requires the bank to review your senior officers and inspect you on site. Vendors put this step at one to six months; I haven't found a neutral source. Breaks: the bank declines because the program is outside its risk appetite (a prohibited business type, thin capital, a thin compliance team), or the term sheet carries minimums the program can't meet for a year.
- BIN assigned: the bank registers the payroll platform with Visa as a Third Party Agent before it performs any service, assigns a BIN or, more often, an account range inside one of its own, files a Regulation II certification for debit and prepaid ranges, gets Visa's approval for a prepaid program and submits the card design. Visa approves designs for every form factor before production and again each time the design changes. Durations aren't published; in practice it's weeks inside the bank's timeline. Breaks: someone tweaks the card art after approval and the design goes back for review.
- Cards ready: the processor certifies your integration while plastics and wallet tokens are prepared. Custom plastic takes 8-10 weeks with a 2,500-card minimum at Stripe and 90-120 days at Column. Apple grants the push-provisioning entitlement (adding the card to Apple Wallet from your app) per app, and it only works in distribution builds, so you test through TestFlight or the App Store. Google's review takes 24-48 hours, then comes an NDA, allowlisting, video test cases and field testing. Breaks: a chip shortage like 2021-23, which put up to a billion cards at risk; an "Add to Apple Wallet" button shown to cards that aren't eligible, which can get the app rejected.
- Live: the earliest users come in as a pilot, then the program opens. I'd start small (for the payroll platform, its own staff and two restaurant groups) and widen once reconciliation has run clean for a few weeks. Breaks: the daily tie-out between the ledger and the bank's account fails in week one and nobody owns the gap.
Two exits sit off that path. Declined is the bank saying no at due diligence, usually because the program is outside its risk appetite. Migrated comes later, when a live program moves to a new bank or processor, covered below.
| Step | How long | How sure I am |
|---|---|---|
| Partner selection and term sheet | 1-3 months | My estimate |
| Bank due diligence and program agreement | 1-6 months; longer if the bank is under an order | Vendor accounts only |
| Agent registration, BIN or account range | Weeks, inside the bank's timeline | Requirements are published, durations aren't |
| Card design approval | A day for a stock design, 2-3 weeks for custom | One platform's documentation |
| Custom plastic cards | 8-10 weeks to 90-120 days; 3-4 months to integrate directly with a card maker | Platforms' documentation |
| Processor integration and certification | 30 days to 12 weeks | Vendor claims |
| Apple and Google wallet approvals | 1-2 weeks, and a production app | Platforms' documentation |
| Total, custom program on its own sponsor bank | Roughly 4-9 months | My estimate from the steps above |
| Total, stock or virtual cards on an existing platform | Days | Platforms' documentation |
Virtual cards work the moment they're issued, so Stripe, among others, advises launching on stock or virtual cards while the custom plastic is made.
When a program moves
Programs move when the bank ends the relationship, when the bank gets into trouble with its regulator, or when the program outgrows its processor, and each move is a project of its own. Chime's filings show the shape of the contracts: 60 months with The Bancorp, running to July 2028, and 36 months with Stride Bank, renewing yearly, with 365 and 180 days' notice for non-renewal. On a termination without cause, Chime can move to a successor bank or wind down, "subject to regulatory approval".
A bank move is either a BIN migration (the same card numbers move to the new bank) or a reissue (new cards, new numbers). One processor notes that some BIN migrations may count as mergers under the Bank Merger Act, and that trailing settlement on the old BIN can run six months or more. Visa won't let the old bank release a BIN until it's been inactive for at least 120 days, and if the old processor won't hand over the data, the fallback is to reissue every card. A processor change at the same bank is lighter and may keep the BINs; one European processor quotes four to six months, longer for credit.
Mercury moved its customers from Evolve to Choice and Column after the Fed's 2024 order against Evolve; a new virtual card was available immediately and the physical one within one to two weeks. Chime moved all its processing and its ledger from Galileo to ChimeCore by November 2025. Block is moving some new Cash App business away from Marqeta, whose contract with it runs through June 2028 by the latest report, and Green Dot's partners will face a new counterparty once its split is approved.
Some fintechs are leaving the sponsor model altogether. Regulators cleared 29 bank charter applications in 2026 up to September 11, against 14 in all of 2025, including OCC conditional approvals for Nubank (January 2026), Mercury (April 28, 2026) and Revolut (September 2, 2026). Months of organizing and further approvals follow before a bank opens. Varo, the first consumer fintech with a national bank charter, still lost about $92 million in 2025, so a charter doesn't fix the economics on its own.
Program models and card types compared
Who holds the BIN
- Own BIN (your own bank)
- You
- Sponsor bank + your program management
- Sponsor bank
- Managed (a processor or BaaS firm brings the bank)
- Sponsor bank
- Embedded (a platform's issuing API)
- The platform's bank
Network registration
- Own BIN (your own bank)
- Your own membership
- Sponsor bank + your program management
- The bank registers you as its agent
- Managed (a processor or BaaS firm brings the bank)
- The bank registers the processor and you
- Embedded (a platform's issuing API)
- The platform is the agent; you're its customer
Who keeps the ledger
- Own BIN (your own bank)
- Your core system
- Sponsor bank + your program management
- You or your processor
- Managed (a processor or BaaS firm brings the bank)
- The processor or middleware
- Embedded (a platform's issuing API)
- The platform
Time to first card
- Own BIN (your own bank)
- 12-24+ months, starting with a charter
- Sponsor bank + your program management
- 3-6+ months (vendor accounts)
- Managed (a processor or BaaS firm brings the bank)
- 1-3 months (vendor claims)
- Embedded (a platform's issuing API)
- Days on stock or virtual cards
Interchange you keep
- Own BIN (your own bank)
- All, but capped if you pass $10B in assets
- Sponsor bank + your program management
- Most, minus the bank's few basis points
- Managed (a processor or BaaS firm brings the bank)
- Shared with the processor
- Embedded (a platform's issuing API)
- The platform's share, often small
Cost to leave
- Own BIN (your own bank)
- Low
- Sponsor bank + your program management
- 4-9 months of migration plus trailing activity
- Managed (a processor or BaaS firm brings the bank)
- Higher; the data sits with the processor
- Embedded (a platform's issuing API)
- Highest; you rebuild
Example
- Own BIN (your own bank)
- Varo; Nubank, Mercury (approved)
- Sponsor bank + your program management
- Chime
- Managed (a processor or BaaS firm brings the bank)
- Cash App on Marqeta and Sutton
- Embedded (a platform's issuing API)
- Stripe Issuing customers
Where the money sits
- Prepaid
- A pooled account the bank controls, plus reserves
- Debit (linked to a deposit account)
- A pooled deposit account (FBO or omnibus)
- Credit
- A receivable at the bank, often sold or shared
- Commercial
- Depends on whether it's charge, prepaid or debit
Consumer law
- Prepaid
- Reg E and the Prepaid Rule
- Debit (linked to a deposit account)
- Reg E
- Credit
- Reg Z
- Commercial
- Mostly none
Durbin cap
- Prepaid
- Exempt at a small bank, or at any bank if reloadable and the conditions are met
- Debit (linked to a deposit account)
- Exempt only at a bank under $10B
- Credit
- Not capped
- Commercial
- Business debit and prepaid capped at big banks; credit not
Who carries losses
- Prepaid
- The program, through reserves
- Debit (linked to a deposit account)
- The program (fraud, negative balances)
- Credit
- The bank, or the program manager through participations or guarantees
- Commercial
- The company or program manager
Deposit insurance
- Prepaid
- Pass-through, if the bank's records meet the FDIC's conditions
- Debit (linked to a deposit account)
- Pass-through, same conditions
- Credit
- Doesn't apply
- Commercial
- Business deposits, insured differently
Cash App's card is legally "prepaid debit", while Chime's is linked to a deposit account, and the two get different treatment under Reg E and Reg II. Credit adds underwriting and a balance sheet to absorb losses, which a later guide covers.
Which program model? Five questions
- What card, for whom? For consumer debit and prepaid, the bank's size decides the interchange. Credit and commercial cards aren't capped by Durbin, so for them I'd choose a bank on risk appetite and balance sheet.
- Where does the money sit? A pooled account at the bank with your ledger on top is the usual answer for debit and prepaid. Decide early whether the ledger lives with you, your processor or a platform, because moving it later is a migration.
- How soon, and how custom? If you need cards in weeks, issue stock or virtual cards on a platform. A custom design, your own bank relationship, physical plastic and push provisioning each add weeks to months.
- What will each card spend? A primary account spends thousands of dollars a month; a payout or payroll card might spend a few hundred. Minimums and fixed fees punish low-spend programs, so model the spend before the term sheet.
- Where are your cardholders? In the US, the Durbin exemption shapes the product. In Canada, in-store debit earns almost nothing and fintech accounts ship as prepaid cards. In the UK and EU a fintech can hold an e-money licence and issue without a sponsor bank, under capped interchange.
My defaults: for a US consumer program under a few hundred thousand cards, a sponsor bank under $10 billion in assets, ideally two, with a clean enforcement record and a contract that says what happens if it crosses the threshold. For a software platform adding cards to its product, start with embedded issuing on virtual and stock cards, and add custom plastic later. Keep the ledger somewhere the bank can read every day, in a format you could hand to a new bank. And read the exit clauses before the pricing.
The primitives
01
Entity & identity
What is the unit of record, and how do we know it is the same one?
A card has at least three legal identities behind it, and embedded issuing adds a fourth. The network member is the bank, the issuer of record. The program manager is the bank's registered agent; Visa calls it a Third Party Agent and needs a separate registration for each bank relationship. Then there's the cardholder, and on a platform, the business customer whose workers or users get the cards.
With the platform's logo on the front, the bank is still the issuer, named in the cardholder agreement and liable to Visa. Adding another sponsor bank means another agent registration, another contract, another set of audits and probably another design approval.
Prepaid adds a role. FinCEN's prepaid access rule has each program name one "provider of prepaid access" by contract, which registers as a money services business. A bank can't be that provider, but where a bank has "primary oversight and control" of the program, nobody has to register, and most banking-as-a-service contracts are written that way.
The card itself has two identities: the card number, in an account range inside the bank's BIN, and the network tokens that wallets and merchants store in its place. Visa assigns responsibility for a token to the bank behind the BIN, so tokens follow the bank.
A check I'd run early on: is the same legal entity named as issuer on the card, in the cardholder agreement and in any FinCEN registration? It usually is; when it isn't, I'd find out why before launch.
02
State & lifecycle
What states exist, and what moves an entity between them?
Card states get all the attention: ordered, personalized, shipped, unactivated, active, suspended, terminated or expired, reissued. Program states matter as much, and few systems model them: contracted, go-live, launched, under order, winding down.
A program can be "launched" and frozen at the same time. When the Fed put Evolve under a cease-and-desist in June 2024, the bank couldn't take a new fintech partner, product or program manager without its regulators' prior approval. Programs on it stayed live but couldn't change, and their roadmaps waited on someone else's examiner.
The bank has a state too. Its Durbin status is measured on assets at the end of each calendar year, and a bank that crosses $10 billion must apply the cap by July 1 of the next year. That gives a program about six months to reprice or move once the year-end numbers are in.
Network rules move card states too: Visa's longer maximum expiry for prepaid cards, from July 25, 2026, changes reissue planning on long-lived payroll cards.
A reissue during a migration changes the card number, and cards stored at merchants break unless tokens or the network's account updater carry the new number over.
03
System of record & ledger
Who owns the truth, and how do systems reconcile?
A cardholder's balance lives in four places, and they have to tie every day:
- The bank's core: the total in the pooled (FBO, "for the benefit of") account.
- The processor: the authorization balance, or open-to-buy, used to approve the next purchase.
- The program's ledger: the per-person sub-ledger that says who owns what.
- The network's settlement reports: what was actually cleared and owed.
The daily check is simple to say: the sum of every user's balance, plus pending items, equals the pooled account balance, give or take items in transit.
The bank's core, account by account
- Example
- A traditional bank
- Why choose it
- The bank sees everything
- How it fails
- Product changes are slow
The processor
- Example
- Marqeta's or Galileo's clients
- Why choose it
- Proven, and the bank reaches it through the processor
- How it fails
- Lock-in; migrations hurt
The program, in-house
- Example
- Chime's ChimeCore
- Why choose it
- Control and speed
- How it fails
- The bank has to be able to read it
Middleware across banks
- Example
- Synapse
- Why choose it
- Fast to launch with several banks
- How it fails
- One failure freezes users at many banks
Synapse is the case to know. In May 2024 its partner banks froze about $219 million "due to financial ledger reconciliation issues", and the bankruptcy trustee later reported that a gap between what the banks held and what Synapse's ledger said existed before the bankruptcy; estimates ran from $65 million to $95 million. The ledger sat on MongoDB and AWS, and the trustee lost access to systems when the staff who held the credentials were let go. The CFPB later paid $46.2 million from its penalty fund to the people affected.
Pass-through deposit insurance didn't help, because it covers the bank failing and Synapse wasn't a bank. Money held in an agent's name is insured as if each owner held it, provided the bank's records disclose the arrangement and each owner's share can be worked out from the bank's or the agent's records. If the ledger is wrong or unreachable, the money sits frozen at a solvent bank.
In September 2024 the FDIC proposed a rule for these custodial accounts: per-owner records in a standard file, daily reconciliation, direct access to records an outside company keeps even if it goes bankrupt, and a yearly certification by a senior officer, at about $250 million across 600 to 1,100 banks in the first year. It has no date on the regulatory agenda, and I found no final rule as of October 6, 2026. Banks ask for most of it by contract anyway; a law firm's August 2026 summary lists real-time, auditable ledger reconciliation among sponsor banks' standard demands.
My test for any program: if the ledger vendor went dark tonight, could the bank pay every cardholder tomorrow from data it already holds?
04
Rules & policy
What logic decides outcomes, and who can change it?
Rules reach a program in three layers: network rules, then the bank's policy, then your own. The bank's is usually the one you work to day to day, and it often repeats the network's rules with stricter numbers.
What Visa writes onto the bank, which the bank passes to you:
- The bank must control approval of cardholder applications, and can't approve an agent just because the contract limits the bank's liability.
- For prepaid, the bank needs Visa's approval before launch, must hold all card funds and agent reserves in an account it controls, and keeps reserves for program losses. It completes a prepaid risk self-assessment at entry and every year, and Visa can review the program at the bank's cost.
- An agent's contract must give Visa audit rights, and the agent must hand cardholder data to Visa or regulators within seven business days when asked.
- Visa can block a BIN used for a purpose it didn't approve, and can refuse an agent registration "with or without cause".
The bank adds prohibited program types, how deep identity checks go, approved vendors, reserves, minimums, and approval of every product change. Chime's filing puts the balance plainly: the banks approve each program, and Chime designs it, negotiates terms and picks vendors, "subject to the requirements of the banks and applicable card networks".
Some policy choices are yours, and they're product decisions. Reg E lets an issuer withhold error resolution and limited liability on a prepaid account until it has finished verifying the customer's identity, so when you run identity checks decides which protections a cardholder has on day one. The checks themselves are in Identity and trust.
When a requirement lands on your desk, I'd ask whether it's a law, a network rule or the bank's risk appetite. That tells you who can change it, and usually only the last is open to negotiation.
05
Effective dating
Which version of the rule applied at that moment?
Most of the money in a card program depends on dates someone else sets. These are the ones I'd keep on a calendar as of October 2026:
| Change | Effective | Status (Oct 2026) |
|---|---|---|
| Visa US interchange table | April 18, 2026 | Live; Visa usually updates in April and October, and no October 2026 table was out by October 6 |
| Visa rules edition | April 18, 2026 | Live; next edition October 24, 2026 |
| Visa: prepaid cards may expire after up to 10 years | Cards issued from July 25, 2026 | Live |
| UK safeguarding rules for e-money firms | May 7, 2026 | Live |
| Canada's retail payments law (RPAA) | September 8, 2025 | Live |
| Durbin threshold | Assets at December 31; cap from July 1 of the next year | Every year |
| Replacement for the 2023 third-party risk guidance | Comments due November 10, 2026 | Proposed |
| Fed's proposal to lower the Durbin cap | Proposed November 2023 | Not final |
| FDIC custodial-account recordkeeping | Proposed September 2024 | No date |
Contract dates matter as much: notice windows (180 or 365 days), minimum-fee step-ups, exclusivity periods and the right to terminate if the bank loses its Durbin exemption, which The Bancorp's filing says some of its agreements allow.
A neobank whose bank sits at $9.6 billion in assets in September should be modelling two scenarios for the following July. If the bank ends the year above $10 billion, debit interchange drops to the cap within about six months, and the contract decides whether the program can move first.
06
Interfaces & standards
What format and protocol do counterparties speak?
A program touches more standards than it builds against directly.
- Messages. Networks and processors talk ISO 8583; the program usually sees the processor's own webhooks and API, covered in the later guide on authorization.
- Chip and contactless. EMVCo's specifications, which the card maker and processor implement.
- Card data security. PCI DSS v4.0.1 applies to anyone who stores, processes or could touch a full card number. Card-issuing platforms show the number inside their own hosted frames, so the program's servers never see it; support tools, logs and push-provisioning payloads can still pull you into scope.
- Card production. PCI's Card Production and Provisioning standard, physical and logical. Visa requires manufacturers, personalizers and fulfilment vendors to be Visa-approved and listed on its registry of service providers.
- Tokens. EMV Payment Tokenisation, run by Visa Token Service and Mastercard MDES. In the US, Visa requires its token service for card-absent use on consumer BINs, and an "Active" issuer must keep a monthly token provisioning approval rate of at least 90% per BIN.
Interchange depends on interfaces too. The rate a transaction qualifies for depends on data in the authorization and clearing messages, such as whether the card was present or tokenized, so a processor that drops a field can cost the program interchange.
07
Networks & counterparties
Who sits between us and the outcome, and what do they want?
Most of a program's counterparties can stop it.
| Party | What they control | What stops if they fail |
|---|---|---|
| Sponsor bank | The licence, BIN, money, approvals, termination | New programs, changes and sometimes the whole program |
| Card network | Rules, rates, registration, token service, stand-in | Everything on that network |
| Issuer processor | Authorizations, card records, files | Spending, unless stand-in approves |
| Card manufacturer and personalizer | Plastic, chips, lead times | New physical cards |
| Wallets | Adding the card to a phone, wallet fees | Tap-to-pay on phones |
| Identity vendors | Checks at sign-up | New accounts |
| ATM networks, instant-payout providers | Surcharge-free cash, instant transfers | Cash access and instant loads |
Concentration runs in both directions. Chime runs on two banks. Marqeta said 64% of its 2025 volume settled through one bank, Sutton, and Block was 45% of its revenue. CompoSecure got 63% of its 2024 sales from two issuers, and The Bancorp's top three partners brought it 59% of its fintech fees. When one side leaves, the other side's numbers move: Galileo's segment revenue fell by about a quarter year on year after its large client left.
Early on I'd write down which single vendor failure stops new card issuance, and which stops cardholders spending; the second list is shorter and scarier.
08
Regulatory layering
Jurisdiction × activity × entity type: is it a license or a certification?
Separate the layers, because each binds a different party and has a different enforcer.
Law
- What it covers
- Reg E and the Prepaid Rule, Reg II, Reg Z for credit, the Bank Secrecy Act, FDIC insurance rules, state money transmission
- Binds
- The bank, and the program through it
- Enforced by
- Bank regulators, the CFPB, states, private suits
Licence
- What it covers
- A bank charter; a money services business registration if you're the provider of prepaid access; an e-money licence abroad
- Binds
- Whoever holds it
- Enforced by
- The licensing regulator
Certification
- What it covers
- PCI DSS, PCI card production, processor certification
- Binds
- Anyone touching card data or cards
- Enforced by
- Networks, through the bank
Network rules
- What it covers
- Agent registration, BIN licensing, prepaid approval and reserves, design approval, token rules
- Binds
- The bank, which passes them on
- Enforced by
- Assessments and fines on the bank
Bank policy
- What it covers
- Due diligence, reserves, minimums, approval of every change, prohibited programs
- Binds
- The program
- Enforced by
- Contract, freezes, termination
Supervisory guidance and orders
- What it covers
- The 2023 third-party risk guidance; consent orders
- Binds
- The bank, then its partners
- Enforced by
- Examiners
For most US programs, the bank's policy is what binds day to day, and it carries the other layers down to you. A program manager acting as the bank's agent usually stays out of state money transmitter licensing, but holding customer money outside the bank pulls it back in; I'd check each state with counsel.
Abroad the layers sit differently. In the UK and EU a fintech can be an e-money institution and a principal network member, so the safeguarding duty lands on it directly. In Canada, payment service providers register with the Bank of Canada under the RPAA; about 300 made its opening batch, KOHO among them.
The test I'd apply to any obligation: would it survive if we changed banks? Law and network rules would; most of the bank's policy wouldn't, and the next bank brings its own.
09
Exceptions & reversals
What goes wrong, and how is it undone?
The exceptions that cost the most in card issuing are program-level ones, and they run on long clocks.
| Exception | The way back | Clock |
|---|---|---|
| Bank under a consent order | Regulator's approval for new programs; re-verify existing cardholders; lookbacks | Months to years |
| Bank exits or doesn't renew | Migrate the BIN, reissue under a new bank, or wind down with regulatory approval | 180-365 days' notice, then months |
| Processor change | Convert at the same bank (BINs may stay) or reissue | 4-9+ months |
| Disputes and late transactions after a move | The old BIN keeps receiving them | Six months or more |
| BIN release | Only after the BIN has been inactive for at least 120 days; no disputes after release | 120+ days |
| Middleware or ledger failure | Freeze until a bank can reconcile from its own data | Months (Synapse) |
| Bank crosses $10B in assets | Reprice, or move debit to an exempt bank | By July 1 of the next year |
Two smaller reversals hit the P&L on every program. A refund on a debit card returns no interchange to the issuer, so the program loses its interchange on that sale. And an ATM withdrawal runs the other way: the issuer pays the ATM's bank $0.30-0.60 in interchange, plus network fees, so a "free ATMs" promise costs money on every withdrawal.
I'd want both banks' contracts to say who handles a chargeback on an old-BIN card three months after the migration.
10
Liability allocation
When it fails, who pays?
The network makes the bank liable, the bank pushes the liability to the program by contract, and when the program can't pay, the bank or the cardholder ends up holding it.
| Failure | Who pays first | How |
|---|---|---|
| Anything on the BIN, including an agent's losses | The bank, to the network | Visa's rules make the BIN holder liable for all of it |
| Fraud and operating losses | The program manager | Indemnities, reserves, collateral |
| Credit losses on a partner program | The program manager, through participations or guarantees; then the bank | Contract, then the bank's balance sheet |
| Unauthorized consumer transactions | Mostly the issuer side | Reg E caps the consumer at $50 or $500, depending on how fast they report; network zero-liability rules go further |
| Stand-in approvals when the processor is down | The bank, then the program by contract | Visa holds the issuer responsible for stand-in decisions |
| Ledger shortfall | End users, if nobody else can pay | Synapse: users first, then $46.2 million from the CFPB's fund |
| Sponsor bank order | The bank (penalties); the program (frozen growth, remediation work) | Consent order, then contract |
Coastal Community Bank showed how the backstop works in 2026. One credit partner's guarantee fell short, and Coastal booked $68.8 million in the April-June quarter, mostly a write-down of the partner's credit-enhancement asset, on a consumer portfolio of about $500 million. The contract put the loss on the partner; the partner couldn't pay, so the bank took it.
On debit fraud, the Fed's 2023 data has issuers bearing about 28% of losses, and for a program that share arrives as a contract line. Every relaxed setting (instant approval, instant loads, skipped checks) is also a decision about who absorbs the next loss.
What's different here
How the money moves
Merchants pay for most consumer card programs, through interchange. The program keeps what's left after the network, the processor, the bank, the card maker, the identity vendors and the wallet take their share.
| Flow | Who pays whom | Rough amount (Oct 2026) |
|---|---|---|
| Interchange, exempt bank | Merchant's bank → card's bank → program | About $0.51 a transaction on average (2024); posted rates like 0.80% + $0.15 in store and 1.65% + $0.15 online for debit |
| Interchange, capped bank | Same | $0.21 + 0.05% + $0.01, about $0.23-0.24 on a typical purchase |
| Network fees, issuer side | Bank → network | About $0.045 a transaction on average (2023); one vendor's Mastercard schedule adds quarterly assessments of 2.5-6.5 basis points |
| Sponsor bank | Program → bank | A few basis points of volume (The Bancorp: about 6-8 in 2025), plus minimums of roughly $2,000-25,000 a month at small scale |
| Issuer processor and program management | Program → processor | A fee per transaction that falls with volume, plus a setup fee; one public processor earned about 16 basis points of volume in 2025 |
| BIN sponsorship | Program → bank | A setup fee plus a monthly minimum; banks don't publish prices, so ask early |
| Cards | Program → platform or card maker | $0.10 a virtual card and $3.50 a standard plastic at one platform's list price; roughly $3-8 delivered |
| Identity checks | Program → vendors | Under a dollar to about $2 per applicant |
| Wallet | Bank → Apple | 0.15% of credit and half a cent per debit purchase (reported); Google and Samsung charge nothing |
| ATM withdrawal | Bank → ATM's bank | $0.30-0.60 interchange, paid by the issuer |
| Push-to-card payout | Sender's bank → card's bank | $0.10 per Visa push payment received |
The bank's split of interchange is the biggest single negotiation. One banking-as-a-service vendor's example gives the fintech 70% and splits the rest evenly between the vendor and the bank; The Bancorp's filing suggests something closer to 6-8 basis points of volume for the bank. On debit the bank also earns the spread on deposits and may share some of it.
A year for 50,000 active cards
Back to the payroll platform, with 50,000 workers using the card actively in year one at a $40 average purchase. Spend per card matters most, so I've run $300, $700 and $1,200 a month; a payroll card that workers drain to their main bank on payday sits near the bottom. Every line is a rough range built on assumptions, in millions of dollars a year.
Purchase volume
- Low
- 180
- Mid
- 420
- High
- 720
- What drives it
- Spend per card
Interchange at an exempt bank
- Low
- 2.2
- Mid
- 5.5
- High
- 10.4
- What drives it
- 1.20-1.45% blended
Network fees
- Low
- −0.2
- Mid
- −0.5
- High
- −0.8
- What drives it
- About $0.045 a transaction
Processor and program management
- Low
- −0.3
- Mid
- −0.6
- High
- −0.9
- What drives it
- $0.04 a transaction plus $0.25 a card a month (assumption)
Sponsor bank
- Low
- −0.2
- Mid
- −0.4
- High
- −0.7
- What drives it
- About 10 basis points of volume
Cards
- Low
- −0.1
- Mid
- −0.1
- High
- −0.1
- What drives it
- About 25,000 plastics a year at $5
Fraud and disputes
- Low
- −0.2
- Mid
- −0.4
- High
- −0.7
- What drives it
- About 10 basis points of volume
Identity checks
- Low
- −0.05
- Mid
- −0.05
- High
- −0.05
- What drives it
- About 25,000 new accounts at $2
Contribution, exempt bank
- Low
- 1.1
- Mid
- 3.4
- High
- 7.1
- What drives it
- Before people, support, compliance and marketing
Per active card a year
- Low
- $22
- Mid
- $68
- High
- $143
- What drives it
Contribution, same program at a capped bank
- Low
- About 0
- Mid
- 0.5
- High
- 1.0
- What drives it
- Interchange at $0.21 + 0.05% + $0.01
Per active card a year
- Low
- $0
- Mid
- $9
- High
- $20
- What drives it
At an exempt bank the program clears its variable costs in every case. At a capped bank it barely does, and people, support and compliance at $5-15 per active card a year (my assumption) would sink it. Each 10 basis points of volume is worth $0.2-0.7 million a year here, and the bank's fee, fraud losses and the processor's fee are each about that size.
A real model also needs deposit income on an account-linked program (a 2-3% share of a $500 average balance across 50,000 cards is $0.5-0.75 million a year), fees for instant transfers and replacement cards, ATM costs, push-to-card income and Apple's half cent. As a benchmark, Chime reported about $257 of revenue per active member in late 2025, interchange and everything else.
Who holds the power
Power in a card program follows whoever can say no, and the bank says no most often.
- The sponsor bank approves every program and change, sets the interchange split, holds reserves and can terminate. Its regulator can freeze it, which freezes you. Scale buys some leverage back: The Bancorp's three largest partners bring it 59% of its fintech fees.
- The networks write the rules, publish the rates, approve designs and prepaid programs, and can block a BIN. In the US, Regulation II and merchant litigation are about the only outside limits on them.
- Regulators reach most programs through the bank: prior approvals, re-verification, lookbacks and forced exits. In 2026 they also started letting fintechs become banks in numbers.
- Processors own the timeouts, the fallbacks and the data, and on exit the old processor's cooperation decides between a BIN transfer and reissuing every card.
- Program managers own the customer, the brand, often the ledger and the data, and the largest move processing in-house.
- Apple decides whether a card can be tapped from an iPhone and charges for it; small issuers can't negotiate the fee.
- Merchants decide how online debit is routed, and since July 2023 they can send it to a cheaper network even on an exempt card.
- Card makers set lead times and minimum runs.
How the rules work
Reg E and the Prepaid Rule. Debit cards have long been under Reg E; the CFPB's Prepaid Rule brought prepaid accounts in from April 1, 2019, including payroll and benefit cards and wallets that hold funds, while gift cards are mostly outside it. It requires a short-form fee disclosure before the customer gets the card, statements or a free alternative (balance by phone, 12 months of history online), limited liability and error resolution, and filing account agreements with the CFPB within 30 days of a change. Overdraft or credit on a prepaid card has to be a separate credit feature under Reg Z.
Sponsor-bank orders. Regulators issued a wave of consent orders in 2024, and in 2025-2026 several ended.
Lineage Bank (FDIC)
- Order
- January 2024
- What it meant for card programs
- Third-party and AML controls
- Status (Oct 2026)
- In effect; a second order in June 2026 on earnings and capital
Sutton Bank (FDIC and Ohio)
- Order
- February 2024
- What it meant for card programs
- Re-verify every prepaid customer since mid-2020
- Status (Oct 2026)
- Reported in effect (a vendor tracker)
Piermont Bank (FDIC)
- Order
- February 2024
- What it meant for card programs
- Lookback over transactions since September 2022
- Status (Oct 2026)
- Reported ended in March 2026 (a vendor tracker)
Thread Bank (FDIC)
- Order
- May 2024
- What it meant for card programs
- A risk rating for each partner
- Status (Oct 2026)
- Ended December 2025
Evolve Bank & Trust (Fed and Arkansas)
- Order
- June 2024
- What it meant for card programs
- No new partner, product or program manager without prior approval; ledger duties
- Status (Oct 2026)
- No termination found; partners migrated
Blue Ridge Bank (OCC)
- Order
- January 2024
- What it meant for card programs
- Partner reviews and exits
- Status (Oct 2026)
- Ended November 2025
A New York savings association (OCC)
- Order
- April 2026
- What it meant for card programs
- Untuned monitoring after payments growth; no partner freeze
- Status (Oct 2026)
- In effect
New orders slowed and older ones are ending, but money-laundering findings keep coming. An order at your bank tends to mean an onboarding freeze or prior approval for anything new, re-verification of existing cardholders, lookbacks, daily reconciliation with the bank's access to the ledger, and an exit plan. How those checks work is in Identity and trust.
Direction of travel. On September 11, 2026 the US bank regulators proposed replacing the 2023 guidance on managing partners like fintechs (comments are due November 10, 2026), and the FDIC's custodial-account rule hasn't moved since 2024. The CFPB's funding was capped at about $467 million for fiscal 2026 and it planned fewer than 70 exams that year. Reg E itself hasn't changed, and I'd expect enforcement to come more from banks' own regulators, states and private lawsuits. The UK went the other way and wrote daily safeguarding reconciliation into its rules from May 7, 2026.
Earned wage access. Relevant to the payroll platform: in a December 23, 2025 advisory opinion, the CFPB said employer-integrated wage access isn't credit under Reg Z when it's repaid only through payroll deduction, with no recourse against the worker and no credit check. About a dozen states regulate it anyway, with fee caps like Connecticut's $4 per advance.
Canada. No statute caps interchange; the federal government's voluntary commitments with Visa and Mastercard cover consumer credit only. The revised Code of Conduct for the Payment Card Industry now binds issuers too, mostly on clear disclosures and complaint handling, under FCAC's supervision. Since June 1, 2021, FINTRAC has required prepaid issuers to identify holders, report suspicious transactions and keep records for accounts that can take C$1,000 or more in 24 hours. Federally regulated issuers follow the Prepaid Payment Products Regulations, which require a fee box and a statement when funds aren't CDIC-insured.
What mistakes cost
- The wrong bank. A bank that crosses $10 billion in assets cuts debit interchange by more than half within months, and a bank under order freezes your roadmap. Either can force a migration that takes most of a year.
- A ledger the bank can't read. In the worst case users lose access to their money and the program loses its bank, as Synapse's users found out.
- Low spend per card. Minimums, card costs and fixed compliance costs can exceed interchange for a year or more, and gift, payout and secondary cards feel it soonest.
- Card production delays. Custom plastic slips by weeks, and a shortage by months. Programs that launch on stock or virtual cards barely notice.
- Network and design missteps. Visa's assessments for an unregistered agent started at $10,000 per agent per client in its 2016 schedule.
- Credit enhancement that fails. For credit programs, the partner's guarantee is only as good as the partner, and the bank tightens everyone's collateral afterwards.
Durbin and the exempt-bank model
My view as of October 2026: for US consumer and small-business debit and prepaid, the Durbin exemption is still the single biggest number in the business case, worth roughly twice the interchange per transaction, and it explains why fintech sponsor banks are small. It matters much less for credit and commercial cards, it's losing some weight to bank risk and fee revenue, and the cap itself is in court.
How the exemption works
The Durbin Amendment, written into the Fed's Regulation II, caps debit and general-use prepaid interchange at $0.21 + 0.05% + a $0.01 fraud adjustment for issuers with $10 billion or more in assets, counted with affiliates. Smaller issuers earn whatever the network's table says. Government benefit cards are exempt at any bank, and so is reloadable prepaid that isn't sold as a gift card, charges no overdraft fees and gives one free in-network ATM withdrawal a month.
The gap is large. In the Fed's 2024 data, exempt issuers averaged $0.51 a transaction, about 1.21% of a $42 average purchase, while capped issuers averaged $0.23, about 0.47% of a $49 one. In 2023, exempt issuers handled 39% of debit and prepaid transactions and earned 59% of the $34 billion interchange pool. On Visa's posted table, a $40 online debit purchase earns an exempt bank about $0.81 and a capped one about $0.24.
Routing is the part people miss. Since July 1, 2023, every debit card, exempt or not, must let merchants route online purchases over at least two unaffiliated networks, usually including a cheaper PIN network. I haven't found public data on how much exempt online debit has moved since.
Why sponsor banks stay small
The Bancorp says it plainly in its annual report: it manages its balance sheet to stay under $10 billion to keep the exemption, and some of its fee-sharing agreements let partners terminate if it loses it. Pathward lists keeping the exemption among its risks. Chime's two banks, The Bancorp and Stride, are both under $10 billion, and Chime says most of its revenue has historically come from interchange.
The limit applies to the bank's assets, which means deposits, and program spend doesn't count. A bank near the line sheds deposits or sweeps them to other banks, and a growing fintech spreads its deposits across several small banks. Since the 2024 orders, though, a clean enforcement record and a working banking-as-a-service team count for about as much as the exemption when a fintech picks a bank. Evolve, Sutton, Piermont, Lineage, Thread and Blue Ridge were all exempt banks.
Interchange-funded products
- Neobanks. A free account paid for by merchants. Chime's debit interchange was 49% of its 2025 revenue, down from 55% in 2024, while early pay, savings and loans grew 48% to $240 million in the quarter to June 2026.
- Earned wage access. Providers waive the transfer fee when wages go to their own card, and earn interchange on what the worker spends instead. With state caps of a few dollars per advance, I think the card's interchange is becoming the steadier revenue line, and it's the payroll platform's plan.
- Payroll and payout cards. Low spend per card means fixed fees and minimums dominate; push-to-card income ($0.10 per Visa push payment received) and float matter more.
All three depend on the court cases, the Fed's proposal, the bank staying under $10 billion and how merchants route online debit.
Where the cap stands (October 2026)
- North Dakota. In Corner Post, a federal court vacated the fee standard on August 6, 2025, finding it included costs the statute doesn't allow. The ruling is stayed while the Fed appeals to the Eighth Circuit, which heard argument in May 2026. I found no decision as of October 6, 2026.
- Kentucky. In Linney's Pizza, a federal court upheld Regulation II in September 2025, and that case is on appeal to the Sixth Circuit. If the two circuits disagree, I'd expect the Supreme Court to take it up eventually.
- The Fed's 2023 proposal. It would cut the cap to 14.4¢ + 4 basis points + 1.3¢, about 28% less on a $50 purchase, and recalculate it every two years. It isn't final, and nine bank and credit union trade groups asked the Fed to withdraw it on December 8, 2025.
If the cap falls, the exempt premium per transaction grows, from about $0.28 to about $0.33 on 2024 averages by my arithmetic, and more mid-size banks stop sponsoring debit. If the cap is struck down with nothing in its place, the premium could shrink. I'd model both for any program whose plan runs past 2027.
Canada and Europe have no exemption to chase
Canada never had a Durbin cap, and debit doesn't need one: Interac, the domestic debit network, charges no interchange in stores. On Visa Canada's table, Visa Debit earns three cents in store while consumer prepaid earns 1.42-1.52%. So Canadian fintech "accounts" ship as prepaid cards; KOHO's is a prepaid Mastercard with customer funds at Peoples Trust, a trust company. KOHO raised C$130 million at a C$1.33 billion valuation in June 2026 and is seeking its own bank licence.
The EU caps consumer debit and prepaid at 0.2% and credit at 0.3% for every bank, and the UK kept the same caps, so European neobanks lean on subscriptions, foreign exchange, interest and commercial cards. Brazil caps debit at 0.5% and prepaid at 0.7%, and Mexico is consulting on caps.
Questions to ask a sponsor bank
- How close are you to $10 billion in assets, and what happens to our split if you cross it?
- Which orders or formal agreements have you had since 2024, and what do they require of partners?
- What do you charge, as basis points, per-transaction fees and monthly minimums, and when do the minimums start?
- What reserves or collateral do you hold against us, and when can you draw on them?
- What do you need from our ledger every day, and in what format?
What usually goes wrong
| Symptom | Likely cause | First thing to check |
|---|---|---|
| Launch date slips by months | Bank due diligence, network approval or custom plastic running in sequence | Whether stock or virtual cards could ship while the rest finishes |
| Bank goes quiet after the early meetings | The program is outside its risk appetite, or the bank is under an order | Its public orders, and its list of prohibited programs |
| Ledger and the pooled account disagree | Timing items, unmatched clearings, refunds not linked to a purchase, fees netted | The daily tie-out, and who owns each break |
| Revenue drops by half in July | The bank crossed $10 billion at the prior year-end | The bank's year-end assets and your contract's termination rights |
| Interchange below plan | Low spend per card, or online debit routed to a cheaper network | Spend per active card and the network mix |
| Cardholders can't add the card to Apple Pay | Wallet approval incomplete, or push provisioning not entitled in a production app | The entitlement and the provisioning approval rate |
| Stored cards fail at merchants after a migration | The card number changed and tokens or account updates didn't follow | Token lifecycle updates for the new range |
| Funds frozen at a solvent bank | The bank can't verify who owns what in the pooled account | Whether the bank holds or can reach per-owner records |
| Credit partner losses land on the bank | The partner's guarantee or collateral fell short | Collateral terms and how fast the bank can draw them |
Words that mean something else here
| Term | What you'd assume | What it means here |
|---|---|---|
| Issuer | The brand on the card | The bank that holds the BIN, named in the cardholder agreement |
| BIN | Your own card range | The first 6-8 digits, licensed to one bank; a program usually gets an account range inside the bank's BIN |
| BIN sponsor, sponsor bank | Two different things | Usually the same bank. In Visa's rules a "Sponsor" is a member responsible for other members, a different idea |
| Program manager | A job title | The company running the program: a Third Party Agent to Visa, sometimes a provider of prepaid access to FinCEN, and never a licence |
| FBO, omnibus, custodial, pooled | Different accounts | One bank account holding many people's money. The FDIC says "custodial deposit accounts with transactional features"; Chime says "omnibus" |
| FDIC-insured | The fintech is insured | The bank is. Pass-through insurance covers the bank failing, and only if the records meet the FDIC's conditions |
| Ledger | One record | The bank's general ledger, the processor's balance or the program's sub-ledger; the system of record is the one that wins a dispute |
| Debit | Linked to a checking account | Cash App's card is legally "prepaid debit"; Chime's is linked to a deposit account |
| Exempt | The card is exempt | The bank is, by asset size. The same card is exempt at one bank and capped at another |
| Interchange | Income | On purchases, yes. On ATM withdrawals and prepaid loads, the issuer pays |
| Migration | Moving data | A BIN migration (same numbers, new bank), a reissue (new numbers) or a processor conversion (same bank) |
| Prepaid (Canada) | A gift card | Often what a US reader would call a fintech checking account |
What surprised me
Placeholders in your voice, drafted from the research and the earlier guides. Rewrite each with your own moment.
"A card program is an API." That was my picture after the sandbox demo: cards in an afternoon. The bank's due diligence, the network's approvals and the plastic set the date, and the code waited on them.
"The bank runs the money." The bank holds it and answers for it, but the books that say who owns which dollar are often ours. Synapse made that concrete for me: the money was at solvent banks, and people still couldn't reach it for months.
"Interchange is a market price." It's a table the network publishes twice a year, and for debit a law caps it for big banks. Whether our bank was under $10 billion mattered more to the business case than anything in the product.
"Leaving a partner is like switching vendors." Here the old BIN keeps receiving disputes for six months after the move, and the network won't release it until it has sat idle for 120 days.
"Canada is the US with different banks." In Canada debit earns almost nothing in stores, so fintech accounts are prepaid cards, which is a different product with a different set of rules.
Sources
Undated entries were read on October 6, 2026; "search result" means seen only as a search snippet. Company figures are self-reported unless they come from a regulator.
US rules and regulators
- Federal Reserve: Regulation II average interchange fees, 2024 data (updated Dec 2025); 2023 interchange fee revenue and the 2023 report on costs and fraud losses (Dec 2025); card-not-present routing final rule (Oct 2022); Evolve order (Jun 2024)
- Federal Register: proposal to lower the Regulation II cap (Nov 2023); FDIC custodial-account recordkeeping proposal (Oct 2024); interagency third-party risk guidance (Jun 2023, search result) and the Fed's release on the proposal to replace it (Sep 2026); FDIC General Counsel's Opinion No. 8 (Nov 2008, search result)
- Reginfo.gov, Fall 2025 agenda entry for the custodial-account rule
- FDIC: Vice Chairman Hill's statement on the custodial-account proposal (Sep 2024); Hill's testimony to the House Financial Services Committee (Dec 2025)
- Cornell LII: 12 CFR 1005.6, consumer liability for unauthorized transfers; 12 CFR 235.5, Regulation II exemptions; 12 CFR 1005.18, prepaid accounts; 12 CFR 330.5 and 330.7, pass-through insurance
- eCFR, 12 CFR 1005.19, submitting prepaid account agreements
- CFPB: Prepaid Rule (search result); Reg Z 1026.61
- FinCEN, prepaid access final rule (2011)
- In re Synapse Financial Technologies, Chapter 11 trustee's fifteenth status report (Feb 2025)
Canada
- Justice Laws, Prepaid Payment Products Regulations (current to Sep 2026)
- FINTRAC, prepaid payment product obligations (Jun 2021)
- Visa Canada, interchange rates (Sep 2026)
- Interac, corporate year in review (2025, search result)
- Finance Canada, credit card fee commitments (Oct 2024)
- DLA Piper, changes to the Code of Conduct for the payment card industry (Dec 2024)
- BetaKit: Bank of Canada's first registered payment service providers (Oct 2025); KOHO's Series E (Jun 2026)
UK, EU and Latin America
- Proskauer, the European Commission's study of the Interchange Fee Regulation
- FCA, changes to payment safeguarding rules; Linklaters, tougher safeguarding rules (2025)
- PYMNTS, Brazil's prepaid and debit caps (2022); Expansión, Mexico's softened cap proposal (Aug 2026)
Card networks
- Visa: Core Rules and Product and Service Rules (Apr 2026); US interchange reimbursement fees (Apr 2026); Third Party Agent registration overview (May 2016); USDC settlement in the US (Dec 2025); FY2025 10-K; fiscal Q3 2026 results (Jul 2026, search result)
- Mastercard, Q2 2026 results (Jul 2026, search result); Nasdaq, Mastercard tokenization (2026, search result)
- Payments Journal, Capital One moves debit cards to Discover (Jul 2026)
Company filings and results (the main players)
- Sponsor banks: The Bancorp, FY2025 10-K; Pathward, FY2025 10-K; Coastal Financial, Q2 2026 results (Jul 2026, search result); Banking Dive, Piermont and Sutton orders and Thread's order (2024); Cash App, card agreement (search result); Column, card programs
- Processors and platforms: FIS, Issuer Solutions acquisition closed (Jan 2026); Fiserv, FY2025 10-K; Marqeta, FY2025 10-K and Q2 2026 results (Aug 2026); SoFi, Q2 2026 10-Q (search result); Stripe, 2025 update (Feb 2026); Adyen, H1 2025 results (search result)
- Program managers and BaaS: Chime, FY2025 10-K, Q4 2025 results (search result) and Q2 2026 results (Aug 2026, search result); Green Dot, merger proxy (2026, search result) and FinTech Futures, breakup deal (search result); Lithic, program management; Synctera, interchange overview and Mastercard pass-through fees; TechCrunch, BaaS after Synapse (May 2024, search result)
- Card makers: CPI Card Group, FY2025 results (Mar 2026); CompoSecure, Q3 2025 presentation and FY2024 10-K; Giesecke+Devrient, 2025 results (Apr 2026, search result)
- Wallets: Payments Dive, Apple's issuer fees in the DOJ complaint (2024); MacTrast, issuer class certified against Apple (Sep 2026)
Platform and vendor documentation
- Stripe: physical cards, digital wallets for iOS and Android, Issuing Elements, pricing
- Marqeta, building a managed card program
- Lithic: physical cards (Sep 2022); landing a sponsor bank (Feb 2024); sponsor bank BIN migrations (Jun 2024)
- Veriff, plans, for identity-check list prices
- Synctera, how to stand up a card product; Enfuce, migration timelines (search result)
Law firms, trade press and research
- Regulation II litigation: ABA Banking Journal on the Eighth Circuit reply brief (Apr 2026) and the Kentucky ruling (Oct 2025); Orrick InfoBytes, Linney's Pizza ruling (Sep 2025); BPI, trade groups ask the Fed to withdraw its proposal (Dec 2025)
- Earned wage access: Goodwin, CFPB advisory opinion (Dec 2025); K&L Gates, Reg Z treatment (Jan 2026); American Banker, state EWA rules (search result)
- CFPB capacity: Bloomberg Law, the CFPB's cuts (2026, search result)
- Perkins Coie, prepaid access rule
- Sponsor banks and Synapse: National Law Review, bank-fintech liability (Aug 2026); American Banker, CFPB refunds to Synapse users (2025); sponsor-bank order tracker (vendor)
- Bank charters: S&P Global, charter approvals (Sep 2026, search result); Nu, US national bank approval (Jan 2026, search result); American Banker, Varo's 2025 results (search result)
- Migrations: Mercury, switching partner banks (search result); Payments Dive, Marqeta flags Cash App hit (2026)
- Chip shortage: ABI Research, a billion cards at risk; NFCW, chip costs (Jun 2022, search result)
Field Guides are learning notes, not legal or compliance advice. Rules and fees change; check the cited primary sources before you act on anything here.