A Platform Offer Issued Cards to It… AI recommendations | Parse
How can a platform offer issued cards to its users without becoming a bank?
Data as of Sep 26, 2026 · Based on 52 AI responses from ChatGPT Search and Google AI Mode · See how Parse measures this
Sources AI cites for this prompt
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BaaS: How can companies offer banking services without ...https://www.rightangleglobal.com/post/baas-how-can-companies-offer-banking-services-without-being-a-bank
2%
BIN Sponsorship: A Key to Unlocking Card Issuance in FinTechhttps://sdk.finance/blog/bin-sponsorship-a-key-to-unlocking-card-issuance-in-fintech/
2%
Stripe Issuing | Virtual and Physical Card Issuing Platformhttps://stripe.com/issuing
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Everything You Need to Know About Issuing Virtual Payment ...https://www.galileo-ft.com/blog/how-offering-virtual-payment-cards-can-boost-your-business/
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What Is a Card Issuance Provider? Benefits for Industries ...https://www.getpliant.com/en/blog/card-issuance-provider
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Has card issuing enabled a new mode of embedded finance?https://www.marqeta.com/blog/card-issuing-embedded-finance
2%
Open Banking vs BaaS: Key Differences Explainedhttps://connectpay.com/blog/open-banking-vs-banking-as-a-service/
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What is BIN Sponsorship? | Stripehttps://stripe.com/resources/more/bin-sponsorship-explained-how-it-works-and-who-needs-it
1%
How to offer banking services and products as a businesshttps://stripe.com/resources/more/how-to-offer-banking-products-and-services-when-your-business-is-not-a-bank
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Third-Party Arrangements: Joint Statement on Banks' Arrangements With Third Parties to Deliver Bank Deposit Products and Services | OCChttps://www.occ.gov/news-issuances/bulletins/2024/bulletin-2024-20.html
A platform can offer cards without being a bank by using a sponsor-bank/BIN-sponsorship model.
Sponsor bank: A licensed bank owns the BIN, holds/controls the relevant accounts or funds, handles settlement, and retains regulatory responsibility.
Card network:Visa/Mastercard provides the payment rails.
Issuer processor: Handles authorizations, transaction processing, card lifecycle, etc.
Platform/program manager: Owns the app, branding, customer experience, and often program operations.
So the user may see “Platform X Card,” but legally the underlying issuing bank is the regulated institution. Stripe, for example, explicitly operates this way in the U.S.
The key is that ; the platform is outsourcing the regulated banking/issuance functions while operating the customer-facing product.
A platform can offer cards to users without becoming a bank by partnering with a licensed financial institution that is the actual card issuer. The platform becomes the customer-facing layer, while the bank provides the regulated banking infrastructure. This is the model behind many fintech, neobank, and embedded-finance products.
The typical structure looks like this:
Question: How can a platform offer issued cards to its users without becoming a bank?
A platform can offer branded physical or virtual payment cards to its users without becoming a licensed bank by leveraging a model known as Banking-as-a-Service (BaaS) or Embedded Finance.
Instead of going through the multi-year process of securing a banking charter and managing heavy regulatory compliance in-house, the platform partners with existing regulated entities and technology middlemen.
Here is how the architecture and partnership model work:
The Sponsor Bank (The Regulated Entity): A chartered financial institution (the "sponsor bank") holds the actual banking license. They legally issue the cards, hold the underlying funds, and ensure compliance with federal and network regulations (like Visa or Mastercard rules).
The BaaS Provider (The Tech Layer): Companies like Marqeta, Lithic, or Unit act as the middleware. They provide the APIs, developer tools, and infrastructure that connect the platform’s software directly to the sponsor bank’s core systems.
The Platform (The Front-End Brand): Your platform designs the user experience, controls the branding (putting your logo on the card), handles customer acquisition, and decides who gets a card and how it functions within your ecosystem.
Key Mechanisms that Keep the Platform "Non-Bank"
Delegated Compliance & KYC: Your platform collects user information (Name, Address, SSN) for Know Your Customer (KYC) and Anti-Money Laundering (AML) checks, but the actual verification rules and final risk approval framework are dictated and overseen by the sponsor bank.
FBO (For Benefit Of) Accounts: The money loaded onto or spent via these cards doesn’t sit on your platform’s balance sheet as a corporate deposit. Instead, it is held in pooled or individual FBO accounts at the insured sponsor bank, protecting user funds.
Program Management: Your platform acts as a "program manager," meaning you handle the commercial relationship with the end-user while outsourcing the regulated financial plumbing.
If you are planning to build a card program, let me know:
Is your target audience B2B (corporate expense cards) or B2C (consumer debit/prepaid)?
Are you looking to launch in the US or internationally?
I can share more details on the cost structure or recommend specific BaaS providers for your use case.
A platform can offer branded physical or virtual payment cards to its users without becoming a bank by partnering with entities that already possess the necessary regulatory licenses and network memberships . This is achieved primarily through a multi-layered ecosystem known as Banking-as-a-Service (BaaS) and embedded finance.
The core framework that makes this possible relies on three main components:
The BIN Sponsor (Partner Bank)
How it works: A licensed FDIC-insured bank (in the U.S.) or authorized financial institution issues the actual Bank Identification Number (BIN) and legally issues the payment cards.
The role: Because they hold the banking license, they assume ultimate regulatory and compliance responsibility for the funds and the ledger, shielding your platform from needing a banking charter.
The Card Issuing/BaaS Platform
How it works: Technology middleware providers (such as Marqeta, Lithic, Unit, or Galileo) sit between your platform and the partner bank.
The role: They provide developer-friendly APIs, handle program management, enable real-time spend controls, integrate with card networks (Visa/Mastercard), and manage mobile wallet tokenization (Apple Pay/Google Pay).
Compliance and Risk Layer (KYC/AML)
How it works: Your platform acts as the "front-end" user experience and brand. When a user signs up for a card, your app collects their information, but the BaaS provider and partner bank run the required Know Your Customer (KYC), Know Your Business (KYB), and Anti-Money Laundering (AML) checks behind the scenes to ensure compliance.
By structuring the relationship this way, your platform operates purely as a software and program manager interface—controlling the user experience, design, and data logic—while the regulated partner bank handles the underlying financial plumbing.
If you're looking to build out a card program, would you like to explore:
The difference between prepaid, debit, and credit card models under this setup?
Compliance responsibilities your platform is still legally required to handle?
An overview of popular BaaS and card-issuing API providers?
Holds the card program relationship with the card network.
Owns the BIN (the card number range identifying the issuer).
Is typically the legal issuer of the debit, prepaid, or credit card.
Handles or oversees regulatory obligations such as compliance monitoring and risk management.
This is often called BIN sponsorship. The bank allows the platform to operate a card program using the bank’s access to payment rails rather than obtaining its own banking charter.
2. Card issuing processor
A technology provider handles:
Creating virtual and physical cards.
Real-time authorization decisions.
Balance updates.
Transaction processing.
Fraud controls.
APIs connecting the platform to the card system.
Examples of this type of infrastructure include card-issuing platforms that provide APIs and program management tools.
3. The platform
The platform usually owns:
User acquisition.
App experience.
Card design and branding.
Spending controls.
Rewards programs.
Customer support.
Business logic (for example, “only allow purchases at approved merchants”).
The card can look like the platform’s product to the user even though the regulated issuing relationship sits with the bank.
Example
Imagine a payroll platform wants to give workers a debit card:
The platform says: “Workers can receive wages and spend using our card.”
A sponsor bank actually issues the debit card.
A processor creates the cards and routes transactions.
The platform manages the app and experience.
The platform does not need a banking charter because it is not itself taking deposits or acting as the issuer of record.
How the platform makes money
Common revenue sources include:
Interchange revenue sharing (a portion of fees generated when users pay merchants).
Subscription fees.
Premium features.
Business software fees.
Lending or financial-product referrals (depending on the structure and jurisdiction).
The economics depend heavily on agreements with the bank, processor, and networks.
Important limitation
A platform cannot simply put a logo on a card and avoid regulation. Regulators generally expect the sponsor bank to oversee the program, conduct due diligence, and manage risks associated with the fintech partner.
So the short version is:
A platform becomes a “bank-like” product company, not a bank: it owns the customer experience, while a licensed bank owns the regulated financial infrastructure.
A platform can offer branded debit, credit, or prepaid cards to its users without securing a formal banking license by utilizing Embedded Finance and Banking-as-a-Service (BaaS) models.
Instead of operating as a bank, the platform acts as the front-end user experience and brand, while regulated financial institutions and technology intermediaries handle the heavy lifting behind the scenes.
The architecture that makes this possible relies on four key components:
Sponsor Banks (The Regulated Entity)
A chartered bank holds the actual banking license, FDIC/deposit insurance capabilities, and ultimate regulatory responsibility.
The sponsor bank legally issues the cards, holds the underlying funds or credit lines, and ensures compliance with federal and network (Visa/Mastercard) rules. Examples include institutions like The Bancorp Bank.
BaaS / Card-Issuing Infrastructure Providers
Technology platforms (such as Marqeta, Lithic, or Unit) sit between your platform and the sponsor bank via APIs.
They provide the core infrastructure to programmatically issue virtual or physical cards, manage transaction routing, handle ledgering, and process real-time authorizations.
Program Management & Compliance Layer
While the sponsor bank is legally responsible, the platform and its BaaS partners must implement strict KYC (Know Your Customer) and KYB (Know Your Business) identity checks, anti-money laundering (AML) monitoring, and fraud detection.
The platform configures spend controls, card limits, and permitted merchant categories through the API dashboard.
Funds Flow and Ledgering
User funds or balances are typically kept in FBO (For Benefit Of) accounts managed by the sponsor bank, ensuring that user money is segregated from the platform’s operational revenue and protected.
When a user swipes a card, the transaction routes through the payment network, gets approved by the BaaS provider's real-time authorization engine against the user's ledgered balance, and settles via the sponsor bank.
If you're exploring this for a specific project, tell me:
Are you looking to issue debit, prepaid, or credit cards?
Is your target audience consumers (B2C) or businesses (B2B)?
I can share more details on the compliance requirements or revenue-sharing models (like interchange monetization) for your use case.
A platform can offer payment cards without itself being a bank by separating the customer-facing product from the regulated banking functions.
In the U.S., the common model is a bank-fintech partnership, often called a sponsor-bank model.
The basic structure
Think of it as:
Platform → program manager/processor → sponsor bank → Visa/Mastercard → merchant
The platform owns the user experience and brand, while a regulated bank is the actual card issuer.
For example:
The platform builds the app, decides who can access the card, manages the user relationship, and often provides customer support.
The sponsor bank is the legal issuer of the card and provides the regulated banking infrastructure. It may hold the relevant funds/accounts and has responsibility for regulatory oversight.
A processor/program manager can provide card issuing technology, transaction processing, ledgering, fraud tools, and connections to the card networks.
Visa or Mastercard provides the payment network through which transactions are authorized and settled.
The OCC specifically describes arrangements where a fintech offers bank-issued, fintech-branded debit or credit cards, with either the bank or fintech operating the cards subject to the bank's sponsorship and oversight.
What this looks like for the user
Suppose a company called Acme wants to give every business customer an Acme Visa debit card.
The customer might see:
Acme Card
Issued through the Acme app
But the legal card agreement could identify:
Issuer: XYZ Bank, N.A.
When the customer spends $100:
The merchant sends the transaction through Visa.
The transaction reaches the issuer/processor.
The issuer authorizes it against the customer's available balance.
The transaction settles through the banking/payment system.
Acme's software updates what the customer sees in its app.
The OCC recognizes precisely this kind of bank sponsorship arrangement, including the bank sponsoring a fintech's access to card networks and potentially maintaining accounts for end-user funds.
Why the platform doesn't automatically become a bank
Having a card isn't, by itself, the same thing as being a bank.
The important question is what financial activity the platform is legally conducting and who is legally responsible for it.
For a debit/prepaid product, the platform generally isn't taking deposits into an account of its own and issuing the card on its own balance sheet. The bank is the issuer, and the parties structure the program so the regulated banking activities remain within the bank's framework.
For credit cards, the distinction is even clearer: the bank can be the lender and card issuer, while the platform supplies the brand, distribution, technology, and customer relationship.
But the platform doesn't get to ignore banking regulation
This is the important caveat.
A sponsor-bank arrangement isn't simply:
"Rent a bank charter and do whatever you want."
Bank regulators expect the bank to exercise oversight over its fintech partners. The OCC, Federal Reserve, and FDIC have specifically highlighted risks involving compliance, operations, liquidity, consumer protection, and customer confusion in bank-fintech arrangements.
Depending on the product and structure, the platform may therefore have obligations involving:
KYC/CIP and identity verification
AML and sanctions compliance
fraud monitoring
transaction monitoring
consumer disclosures
dispute/chargeback handling
privacy and data security
money-transmitter licensing
state-specific financial-services laws
recordkeeping and reconciliation
For example, federal guidance says that for certain bank-issued prepaid cards, the issuing bank's customer-identification requirements apply even when a third-party program manager designs, markets, distributes, and operates the program.
The economic model
The platform and bank typically divide the economics.
The platform might earn revenue from things such as:
interchange economics
subscription fees
account or program fees
foreign-exchange fees
lending economics, where applicable
The bank receives compensation for providing the regulated infrastructure and taking on associated risks. The exact economics depend heavily on the product and agreement.
A useful mental model
The distinction is roughly:
Function
Platform
Bank
App / UX
✅
Brand
✅
Customer acquisition
✅
Card design
Often
So when you see a fintech saying "we offer cards", that doesn't necessarily mean "we are a bank." It may mean we have built a branded financial product on top of a regulated bank's charter and infrastructure.
A good real-world illustration is that even in 2026, major fintechs continue using this model: Reuters reported this month that Nubank's initial U.S. products are being offered through FDIC-insured Lead Bank while Nubank itself awaits final approval for its own U.S. banking charter.
If you're asking because you want to build a platform that issues cards to your own users, I can also break down the actual architecture—sponsor bank vs. issuer processor vs. program manager vs. card network, including what you would need to contract with and which licenses you may or may not need.
A platform can offer branded debit, credit, or virtual cards to its users without holding a banking license by leveraging Banking-as-a-Service (BaaS) and embedded finance infrastructure.
Instead of operating as a bank, the platform acts as a program manager , while regulated financial institutions and specialized technology layers handle the heavy lifting behind the scenes.
The standard architecture to achieve this relies on three core layers:
Sponsor Bank (The License Holder): A chartered partner bank legally issues the card, holds the underlying funds (ensuring FDIC insurance), and assumes ultimate regulatory responsibility.
Issuer-Processor (The Tech Bridge): Companies like Marqeta or Galileo connect your platform via APIs directly to the card networks (Visa, Mastercard) to authorize and process transactions in real time.
Card Issuing API Platforms: Developers can use turnkey platforms like Stripe Issuing or Lithic to spin up virtual and physical cards quickly with built-in controls.
How the Responsibilities are Split
What the Bank Does: Issues the BIN (Bank Identification Number), holds the ledger of funds, complies with federal banking laws, and acts as the legal issuer printed on the back of the card.
What Your Platform Does: Owns the user interface, sets the branding/design, decides the business logic (e.g., rewards, spend limits), and drives user acquisition.
Shared/Delegated Compliance: As the non-bank partner, your platform is still contractually responsible for front-line compliance—such as gathering KYC (Know Your Customer) data, monitoring for fraud, and handling customer service—under the strict oversight of your sponsor bank.
If you're exploring this for a project, let me know:
Are you looking to build a consumer fintech app , a B2B expense management tool , or something else?
Do you need physical cards, virtual cards, or both?
I can recommend the ideal tech stack or compliance considerations for your use case.
Imagine a SaaS platform called Acme that wants to give every business customer a Visa debit card.
┌─────────────────────┐
│ Acme Platform │
│ app, UX, controls │
└──────────┬──────────┘
│
customer/card experience
│
┌──────────▼──────────┐
│ Program Manager │
│ (sometimes Acme) │
└──────────┬──────────┘
│
sponsorship /
card program
│
┌──────────▼──────────┐
│ Sponsor Bank │
│ actual issuer │
└──────────┬──────────┘
│
Visa / Mastercard
│
merchants
The important distinction is that the bank actually issues the card and provides the underlying regulated financial product. The fintech/platform provides the technology, distribution, user interface, and often much of the operational layer.
U.S. regulators explicitly recognize this structure: a fintech can offer a bank-issued, fintech-branded debit or credit card, with either the bank or fintech operating the card program subject to the bank's oversight.
What each party does
Sponsor/issuing bank
The bank generally:
Holds the underlying customer funds/account relationship where applicable.
Is the legal card issuer.
Sponsors access to the card network.
Has responsibility for regulatory compliance and oversight.
Performs or oversees KYC/CIP, BSA/AML, sanctions controls, etc.
Bears certain payment and program risks.
For prepaid products, federal guidance explicitly treats the issuing bank as the institution that authorizes use of the card and says the bank's customer-identification obligations apply to cardholders.
Platform/fintech
The platform can provide:
The mobile/web experience.
Customer acquisition.
Card ordering and provisioning.
Spending controls.
Transaction categorization.
APIs and ledgering.
Customer support.
Fraud tooling.
Program-specific features.
The platform can therefore make the experience look like “Acme issued you a card”, even though the cardholder agreement and regulatory issuer may identify the partner bank.
There's usually another layer: the processor
A typical stack might actually look like:
Customer
│
▼
Fintech / Platform
│
├── Program management
├── UX
├── Ledger
├── Controls
└── Support
│
▼
Issuer Processor
│
▼
Sponsor Bank
│
▼
Visa / Mastercard
The processor handles things such as authorization, card creation, transaction processing, settlement, chargebacks and related infrastructure. The regulatory agencies recognize program managers and processors as distinct roles in these arrangements.
What prevents the platform from simply becoming a bank?
The platform doesn't take on the legal role of the bank.
For example, if a customer has $10,000 in an account associated with the card, the architecture might have the customer's funds held in an account at the partner bank, potentially in an FBO (“for benefit of”) structure, rather than the fintech simply taking the $10,000 onto its own balance sheet. The OCC describes sponsor banks establishing FBO accounts for end users in some fintech payment arrangements.
The exact legal structure matters enormously, though. You can't just put the word “FBO” in a contract and make banking regulation disappear.
And the fintech doesn't get a free pass
This is the part that often gets misunderstood.
“We're not a bank” does not mean “we aren't regulated.”
The bank is expected to conduct due diligence and oversee its fintech partner, and the fintech may have substantial direct obligations depending on what it actually does. Regulators specifically highlight risks around BSA/AML, customer identification, transaction monitoring, reconciliation, operational controls, consumer protection, and third-party risk.
So the practical model is:
Bank = regulated financial institution and issuerFintech = technology/distribution/program operatorProcessor = payment infrastructureVisa/Mastercard = payment network
What about credit cards?
Credit is a little different.
If the platform says:
“We'll give you a $20,000 credit line.”
then the underlying credit product generally needs to be provided by an appropriate regulated lender/issuer, with underwriting, disclosures, servicing, fair-lending and other requirements.
The platform can provide the customer experience and potentially participate economically, but calling yourself a fintech rather than a bank doesn't let you originate regulated credit without considering the applicable licensing and lending laws.
The key business insight
This model is why you see companies that appear to have their own banking product without actually owning a bank.
The platform effectively rents access to regulated financial infrastructure from a bank and builds its differentiated product on top of it.
The tradeoff is that the platform gives up some control: the sponsor bank has regulatory obligations and therefore has to approve the program, monitor it, impose controls, and retain meaningful oversight. Regulators have specifically emphasized that these aren't merely commercial outsourcing relationships—the bank remains responsible for managing the risks associated with its third parties.
If you're asking because you're designing such a platform, I can also break down the actual architecture—ledger, FBO accounts, KYC/KYB, card processor, Visa/Mastercard sponsorship, money-transmitter licensing, interchange economics, and who owns the customer relationship—which is where the interesting details are.
User → Platform → Sponsor/issuing bank → Card network → Merchant
For example, imagine a software platform called Acme that wants to give every business customer a Visa debit card.
1. A bank is the actual issuer
Acme partners with a bank that is licensed and regulated to issue payment cards. The bank provides the card program and is legally the issuer.
The regulators explicitly recognize this model: a third-party program manager can design, manage, market, and operate a card program while contracting with a bank to issue the cards.
So the card might say:
Acme
Visa
Issued by XYZ Bank
Acme can make the card feel like an Acme product, but XYZ Bank is the issuer.
2. The platform becomes the "program manager"
Acme typically handles the customer-facing experience:
creates the card inside its app
collects customer information
provides the dashboard
decides what features to offer
manages customer support
integrates with the card processor
potentially controls spending rules
markets the card
The bank provides the regulated banking infrastructure and oversight.
The OCC describes these bank-fintech arrangements as banks working with fintech companies to distribute banking products and services to consumers and businesses.
3. A card processor handles the plumbing
There is usually another company between the platform/bank and the card networks.
The FDIC describes the processor as facilitating authorization, account setup, card creation, chargebacks, settlement, and related functions.
The platform therefore doesn't need to build its own connection to Visa or Mastercard from scratch.
4. The bank sponsors access to the card network
This is particularly important.
Visa/Mastercard access and the associated payment-system relationships can be provided through the bank's sponsorship. The OCC specifically describes banks sponsoring fintech companies' access to payment systems or card networks and potentially taking responsibility for network compliance and certain transaction risks.
This is where the distinction gets particularly important.
Suppose a customer puts $1,000 into an account associated with the card. Depending on the product structure, the money may be held at the partner bank, potentially in an account structured for the benefit of (FBO) the platform's users. The fintech may maintain the user-facing ledger while the bank maintains the underlying banking relationship/account structure. The OCC specifically describes FBO accounts as one structure used in bank-fintech arrangements.
So Acme can show:
Available balance: $1,000
without Acme itself necessarily being a bank or holding $1,000 of customer deposits on its own balance sheet.
6. Why doesn't this make Acme a bank?
Because Acme isn't necessarily doing the activities that require it to be a bank.
It's essentially renting/partnering for the regulated banking layer while owning the software and customer experience.
A simplified division is:
Function
Platform
Bank
App/UI
✅
Customer experience
✅
Marketing
✅
Card program management
✅
✅/oversight
Card issuance
✅
Bank account/deposit relationship
✅
Network sponsorship
✅
Transaction processing
Processor
Compliance oversight
Shared
Bank ultimately responsible for bank activities
Ledger/user experience
Often ✅
Often underlying records/accounts
The important caveat is that "not being a bank" does not mean "not regulated." The fintech can still have substantial obligations under money-transmission, AML/KYC, consumer-protection, privacy, state and federal payments laws, network rules, and its contracts with the bank. The bank also has regulatory responsibility for managing its third-party relationship.
The business model in one sentence
The platform owns the product and customer relationship; the bank supplies the regulated financial infrastructure and legally issues the card; processors and card networks provide the payment rails.
That's the basic architecture behind a large portion of modern embedded-finance / Banking-as-a-Service (BaaS) products.
If you're asking because you're considering building such a platform yourself, I can also break down the actual stack—sponsor bank vs. BaaS provider vs. processor vs. Visa/Mastercard, licensing requirements, economics/fees, and what you'd need to launch the first 1,000 cards.
A non-financial platform can offer physical and virtual cards to its users by partnering with regulated entities through a model called Banking-as-a-Service (BaaS) and Embedded Finance.
Instead of getting a costly banking license, undergoing years of regulatory approval, and holding capital reserves, a software platform acts as the front-end user experience, while licensed financial institutions handle the heavy regulatory lifting behind the scenes.
The 3 Core Components of Card Issuing Without a Bank
The Partner Bank (Issuer): A chartered financial institution (like WebBank, Cross River Bank, or Evolve Bank & Trust) holds the actual banking license. They officially issue the cards, own the BIN (Bank Identification Number), and take ultimate responsibility for regulatory compliance.
The BaaS / Card Issuing Infrastructure Provider: Tech intermediaries (such as Marqeta, Unit , or Stripe Treasury ) provide the APIs, developer dashboards, and compliance tooling that connect your platform to the partner bank.
Your Platform (The Program Manager): You own the user relationship, design the UI/UX, decide the business logic (e.g., spending limits, rewards, or cash-back programs), and acquire the users.
How the Mechanics Work
Program Management: Your software acts as the "program manager." You interface with the BaaS provider via APIs to request card creation, freeze/unfreeze cards, set velocity limits (e.g., $500 per day), or restrict merchant categories (e.g., blocking gambling sites on corporate expense cards).
Funds Flow and Ledgering: When a user funds their card or account, the money doesn't actually sit in a vault you own. It is routed into an FBO (For Benefit Of) account held at the partner bank in accordance with FDIC-insurance requirements. Your platform maintains a ledger to track what portion of that pooled bank account belongs to which user.
Authorization and Clearing: When a user swipes a card at a merchant, the transaction request hits the card network (Visa/Mastercard) → goes to the card-issuing processor (like Marqeta) → pings your platform’s API for a risk/balance check → and routes to the partner bank for final approval, all in milliseconds.
Compliance and Responsibilities You Still Own
Even though you aren't a bank, you cannot completely wash your hands of compliance. As the platform provider, you are typically responsible for:
KYC / KYB (Know Your Customer / Business): Collecting user identities, running anti-money laundering (AML) checks, and verifying business legitimacy during onboarding.
Customer Support: Handling day-to-day user disputes, lost card replacements, and transaction inquiries (though escalated fraud claims route back to the partner bank).
Marketing & Disclosures: Ensuring your app's user agreements and disclosures correctly state that the banking services are provided by [Partner Bank Name], Member FDIC.
If you're exploring this for a specific project, let me know:
Is your platform targeting consumers (B2C) or businesses (B2B/Expense Management)?
Are you looking to offer prepaid cards, debit cards, or credit products?
I can point you toward the most relevant BaaS architecture or compliance considerations for your use case.
Visa/
Mastercard provides the payment rails.
