Card issuing: launching a card program
10
Glossary and sources
6 min read · Chapter 10 of 10
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)
- Stablecoin-linked cards: The Block, Visa's stablecoin settlement run rate (Sep 2026); crypto.news, Visa stablecoin card payments (2026, search result)
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)
- Co-brand and private-label programs: PYMNTS, JPMorgan to become Apple Card's issuer (Jan 2026, search result); News Tribune, Apple Card switches hands (Jan 2026, search result); Mastercard, OnePay and Synchrony card program with Walmart (Jun 2025, search result); Payments Journal, Walmart's card business lands at OnePay and Synchrony (search result); View from the Wing, what Amex pays Delta (search result); American Express, FY2025 10-K (search result); Synchrony, FY2025 10-K (search result)
- Large programs: Dave, Q2 2026 results and MarketBeat, Q2 2026 call highlights (Aug 2026, search result); Block, Q2 2026 results (Aug 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: Issuing (read Oct 11, 2026), physical cards, digital wallets for iOS and Android, Issuing Elements, pricing
- Marqeta, building a managed card program
- Column, pricing (search result); Increase, push provisioning; FinTech Global, Highnote's Series B (Jan 2025)
- 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)
- Debit and credit card policy: Payments Dive on the Justice Department's Visa debit case, lawyers clash ahead of trial and market definition (2026, search result); PYMNTS, judge signals approval of the Visa and Mastercard swipe-fee settlement (Jun 2026, search result); Consumer Finance Monitor, a 10% credit card rate cap (Jan 2026, search result); Sheppard, the rate cap and the Credit Card Competition Act (Jan 2026, search result)
- 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.