Company offboarding

Introduction

Companies may offboard from the Synctera platform for various reasons, such as:

• Expiration of the contract
• Mutual agreement with Synctera to end the relationship
• Company failure or bankruptcy
• Breach of contract provisions by the company
• Multiple and/or significant regulatory violations by the company

How long does offboarding take?

In all examples noted above, except for events of company failure without advance notice, companies will have 60-120 calendar days (this may be evaluated on a case-by-case basis to mitigate disruption to end customers) to offboard from the Synctera platform and formally end its relationship and accounts with its sponsor bank partner. 

What is required during offboarding?

When Synctera receives notice or becomes aware that a company is going to offboard from the platform, Synctera will coordinate withthe company and its sponsor bank partner to ensure the following requirements are met during the offboarding period:

Consumer notices and disclosures

Synctera will work with the company's sponsor bank partner (and refer to applicable relationship contracts) to determine which, if any, notices or disclosures are required to be sent to the company’s customers. Depending on the product or service offered by the company, this may include:

• Change-in-terms notices under Regulation DD, Regulation E, Regulation CC, and Regulation Z
• Refunds
• Bank account closure notices

Additionally, depending on individual circumstances, the following forward-looking notices may need to be provided depending on the structure of the new relationships:

• Updated account/cardholder agreements
• Updated loan agreements
• Updated terms of use; and/or
• Updated privacy policies and GLBA notices

Return of funds

Upon Bank account closures, the Bank will work with Synctera and the company to ensure it returns funds to consumers using the correct addresses and within the required time frames.

Record retention

Synctera and the Bank must maintain all records necessary to demonstrate compliance with applicable regulations during the time they held or serviced the customer accounts. As such, Synctera and the Bank should coordinate with the company to ensure it has access to all applicable records, disclosures, transactions, and documents during the time period of the relationship. Synctera and the Bank should ensure they maintain these records for five years to ensure compliance with all applicable BSA/AML and consumer protection compliance requirements. 

Information security

Synctera, the Bank, and the company will ensure that their respective information security departments coordinate a secure transition and protect consumer personal information during any data transfers between Synctera, the Bank, the company, and any other third parties. 

Audit

The Bank may conduct an audit during the offboarding period to ensure the company has been maintaining compliance with all applicable regulations. If Synctera or the Bank identifies any issues or violations, the company must remediate the findings prior to the end of the offboarding time period.