Marketing & Collateral

Marketing collateral is any digital or printed materials used to communicate, promote, or disseminate information about a Card Product. The materials should align to your offerings, utilize clear and conspicuous language for cardholders to understand important terms about the card, and ensure fairness in the marketing practices of the program.

In order to issue Payment Cards to your Account Holders, these key materials are required to undergo a review with Highnote’s collateral team. The team verifies the documents reflect the technical specifications of your program, provide clear disclosures for Account Holders, and meet criteria outlined by the network, as well as partner banks.

This guide contains marketing and collateral guidelines for Prepaid Cards and Payments offerings. General guidance when it comes to these materials is that all communication a customer or potential customer would see must be reviewed through the collateral process by Highnote. Highnote is required to provide these copies to partner bank as well for their review. To submit collateral, Subscribers email documents to collateral-review@highnoteplatform.com.

If an Account Holder or potential Account Holder is going to see or read anything related to the Payment Card or Card Product, it should undergo the collateral review process.

Please note, items should be submitted even if there is a question or concern that it may not be relevant.

The following are required to be reviewed for collateral approval:

• Card Designs, Virtual, Physical, and Tokenized
• Card Inserts
• Marketing and Advertisements: flyers, media releases, commercials (TV, Radio, Podcasts, Online, Media, etc.), and emails
• Documents: Account Holder Agreements, Terms and Conditions (Terms of Use), Short Form Disclosures, Long Form Disclosures, Privacy Notice Form, Frequently Asked Questions, Privacy policy
• Customer Communications/Dispute Resolution Material: IVR Flows, Response templates, App Screen Responses, Call Scripts, Training Materials, Predetermined Responses, Reference Documents
• Websites
• Phone App Screens: App Store Description/Screenshots

It is important that verbiage across all of these materials is clear and conspicuous for the Account Holder (and/or consumer) to understand the terms of, as well as general details around, the Card Product.

Collateral cannot be submitted until your Card Product Application to work with Highnote is approved.

Review Process Notes

• Ensure your naming convention includes the name of your business and a brief description of the collateral item, for example, Highnote.CardArt.pdf
• Materials are to be reviewed within 13 to 15 business days from the date of receipt confirmation by Highnote
• Materials are reviewed by both Highnote and partner bank
• If any changes to the materials are required, such as wording or graphics, materials must be resubmitted for final approval prior to production and use
• A clean version, which when appropriate includes the approved date, must be sent back to Highnote for internal records and partner bank records
• Once approved, Highnote responds back with confirmation
• After approval, resubmission of materials are required when changes to the Product or the information being communicated to the Account Holder is changed
• Resubmissions undergo the same 13 to 15 business day Service Level Agreement (SLA) timeframe

General guidelines for marketing and collateral are included in this section.

What to do

• Ensure the Program name and Network name the same text size
• Ensure Program name utilizes proper capitalization following the approved Program with Highnote and the partner bank
• Includes ensuring formatting aligns with using “Prepaid” instead of “Pre-paid” or “PrePaid”
• For Mastercard Debit cards, “debit” should be utilized if listed on the front of the card with the Mastercard logo
• Ensure that the details of the card are reflective of the approved Program with Highnote and the partner bank

What not to do

• Include unfair, deceptive, or misleading (UDAP/UDAAP) information
• Use language suggesting the Card or Product is a bank or offers banking services, exceptions apply for Demand Deposit Accounts (DDA)
• Language that states digital or mobile banking is permitted
• Use language acting superior to other card products the associated network offers, for example, “Easier than opening an account at a traditional bank” or “The most rewarding card”
• Reference offerings the product does not offer
• Say "free" or "no fees" when there is a potential for fees

Use language or images that include, but are not limited to:

• Profanity
• Sexual or political subject matters
• Offensive racial or religious subject matters
• Use negative language about banks, debit, credit, bank accounts, or other financial institutions

Negative language:

• Better than credit
• Better than a bank account

Instead say:

• Better than cash
• Safer than carrying cash
• Manage your money hassle-free
• Spend only what you load
• Use language indicating everyone may be approved
• Reference “zero liability” without including a statement such as “Conditions and exceptions apply. See Cardholder Agreement for details” or “Certain limitations apply. See Cardholder Agreement for details”
• Reference or compare payday loans, title loans, pawn shops or any product that has credit elements, which are not associated with prepaid cards

Demand Deposit Accounts (DDA) have unique guidance when it comes to the terms “Bank” and “Banking.”

• Bank/Banking cannot be in the website name, such as highnoteplatformbank.com
• If the term "bank" or "banking" is used, there must be a disclosure stating that the your company is not a bank and banking services are provided by a partner bank. Disclosure must be bolded or increased font size that draw's the customer's attention and must be near the use of the bank or banking terminology.
• In any publications or testimonials, the Partner must clarify that the program is a FinTech and not a bank and banking services are provided by the partner bank
• Websites cannot use language stating “opening a [Company Name] bank account” or “how to open a bank account with [Company Name].” Instead an option would be to say, "open an account through [Company Name]."
• Google search results must place a statement on Google or other ads that banking services are provided by partner bank
• Frequently Asked Questions (FAQs) must have a section that explains that bank accounts are held at partner bank
• During account set up, there must be a clear and prominent statement to inform consumers that your company is a FinTech, not a bank, and banking services are provided by partner bank
• Company description must be clear that you are not a bank. It is suggested to put a “What is [Company Name]” section in the FAQs

Please note, General Purpose Reloadable Cards are not considered Demand Deposit Accounts. Though they may offer many of the features of a Virtual DDA, they are not labeled nor considered a DDA as there are limits associated with the Card Product and check writing capabilities are not provided.

Issuing statements are required to appear anytime the Card Program or the Network is identified or displayed in any form of collateral. A Program can work with Highnote and the partner bank to request a variance from the Network. See the approved versions below and should there be questions about additional versions, partner with Highnote to see if there are any other Network approved variances.

Mastercard

This card is issued by Sutton Bank, Member FDIC, pursuant to license by Mastercard International.

Visa

This card is issued by Community Federal Savings Bank, Member FDIC, pursuant to a license from Visa U.S.A. Inc

Additional General Guidelines for Issuing Statements

• When displaying Partner Banks, naming convention are to abide by approved formatting
• Similarly, if there is mention to the Partner Bank as a corporate organization, Highnote can provide an approved description
• For Websites, the issuing statement must appear at the bottom of each website page where the Card Program or Network is identified or displayed
• For In-App/Virtual Cards, the issuing statement can be displayed on the app screen where the card, Card Program, or Network is identified. Other location options for the issuing statement include a link on the screen where the card, Card Product, or Network is mentioned that directs the customer to the issuing statement or an icon on the screen where the card, Card Product, or Network is mentioned in which the customer can touch or hover that displays the issuing statement
• For Commercials, the issuing statement must appear at the end of the commercial
• For Physical Cards, the issuing statement must appear on the physical card
• For Emails, the issuing statement must appear at the bottom of each email

At the first mention of the network (Mastercard, Visa, or Discover), the registered trademark symbol (®) must be present. The registered trademark symbol (®) may stop being used when the network is mentioned again in the same document. Brand mark may not be used in place of a brand name.

The Trademark Statement should appear below the Issuing Statement on non-card materials that reference the card product.

Mastercard

Mastercard and the circles design are registered trademarks of Mastercard International Incorporated.

Visa

Visa is a registered trademark of Visa, U.S.A. Inc. All other trademarks and service marks belong to their respective owners.

A Card Product cannot participate in any type of lottery, sweepstake, or contest without the express permission of Highnote, the Partner Bank, and Card Network brand.

Common definitions to consider when evaluating lotteries, sweepstakes, and contests:

• Lottery is a promotion will be considered a lottery if it has, consideration to enter, chance and/or a prize
• Sweepstake is a random drawing or a prize
• Contest is a true competition, skill replaces chance, such as a best photo contest

The FDIC and networks have strict guidelines relating to these practices. See FDIC Federal Deposit Insurance Act for more information.