Document information and change log

Document Information

Change log

Gender And Entity Neutrality

The masculine form is used solely for the sake of better readability. It always refers to persons of any gender identity (m/f/diverse). This document uses the abbreviation “Give” for all legal entities and subsidiaries.

Table of Contents

Purpose        3

Scope        3

Overview        3

1. Merchant Request/ Merchant Notification        3

2. Account Suspension/Deactivated        4

3. Identity Verification/Compliance        4

4. Notify the Customer        4

5. Rolling Reserve        5

6. Settle Outstanding Items        5

7. Reconcile Account Balance        5

9. Final Review        6

10. Send Closure Confirmation        6

11. Post-Closure        6

12. Retention and Recordkeeping        7

Purpose

This policy provides standardized guidelines for Give and any of its subsidiaries' to ensure a consistent, transparent, and compliant merchant account closure process.

Scope  

This policy applies to all employees, contractors, and affiliates of Give and any of its subsidiaries who support merchants.

Overview

The initiation of an account closure begins with a 30-day suspension/deactivation period. This time frame allows for a structured and retraceable series of actions to ensure compliance, transparency, and user accountability. The closure of an account follows a standardized process beginning with a 30-day suspension/deactivation period, followed by a post-closure holding period before any remaining funds are released. The holding period is determined by the Merchant Category Code (“MCC”) and ranges between 60 days to 540 days. Higher risk MCCs require longer post-closure holding periods.

1. Merchant Request/ Merchant Notification

If the merchant chooses to close their account, the merchant must submit a request through the Freshdesk portal. If the request is received by email, the request will be channeled through the Freshdesk portal.  The email address will be examined to confirm it matches the email address(es) on file. A ticket will be generated for the request. A merchant initiated account closing will be handled as a possible merchant complaint as the merchant may be dissatisfied with Give. Client Services will proceed with account closure for balances less than $1,000. Amounts greater than $1,000 Client Services will escalate to the Risk team.

There may be instances where GiveCorporation (“Give”) may initiate the account suspension/closure process. Some of the reasons include potential fraud or criminal activity, compliance, reputational, merchant’s risk is beyond Give’s risk tolerance, too many chargebacks and or returns. Give will notify the merchant that their account is suspended and the next steps. A ticket will be generated through the Freshdesk portal, login access and processing will be disabled. The merchant’s funds will be held in reserve.

2. Account Suspension/Deactivated

If either Give, its subsidiaries or the merchant initiates the account termination process, the following should be suspended, access rights, logins, processing services, account access, tokens and API.

Exit for Fraud

Give’s Compliance Team will investigate to determine the activity is indeed fraudulent, criminal, security or identity compromise or the risk is more than our risk appetite. During the period of suspension, the merchant may contact Give to appeal the suspension and explain the activity is not fraudulent, criminal, or explain the chargebacks and returns.

Exit for Exceeding Risk Appetite

Processing, payouts, and transfers may be disabled during an active investigation, while remediation evidence is pending, where fraud is suspected but not yet confirmed, or when Give initiates action for non-fraud reasons (for example, where the merchant’s risk profile exceeds Give’s or the Sponsor Bank’s risk appetite). In such cases, new transactions will be blocked and any unsettled funds will be held pending review. At this stage, the account will be disabled, but not formally suspended.

An account will be suspended if any of the following occur: the identified risk remains unresolved after the applicable grace period, fraud is confirmed, remediation efforts fail, or the investigation determines that wrongdoing has occurred. Once suspended, the account will not be permitted to process transactions or receive payouts, and funds will be administered in accordance with applicable reserve, settlement, and Give policies.

Merchant Initiated Exit

Merchant initiated account closing that is not associated with fraud will trigger an access deactivation process.  

3. Identity Verification/Compliance

The merchant’s identity will be verified using the 2 Factor Authentication (“FA”) login if the merchant requested the account closure.  When an account closure is received via an email that is not the primary holder email, request the email be sent from the primary holder email address that is on file. Part of the verification process is not telling the requestor which is the primary holder email address on file.

For compliance, legal, fraudulent, criminal, security or identity compromise issues, the merchant should be escalated to the Compliance Team using this link https://docs.google.com/spreadsheets/d/1lCgfFP2W5T1_2kXaKk5fSi9GX-hXwIMEIGgUYe7xZIY/edit?gid=1749864949#gid=1749864949 .

4. Notify the Customer

If the process was initiated by the merchant, Give will acknowledge the merchant’s request by responding to the merchant’s response. If there is no fraudulent activity associated with the account and the account balance is less than $1,000, the merchant will be instructed to transfer’withdraw the funds to initiate the deactivation process.

If the account balance is over $1,000, the merchant will be escalated to the Risk team and transfers will be disabled. After the Risk Team reviews the account, the Risk team will approve or deny the balance to be withdrawn.

If the process is initiated by Give, the merchant will be notified  that the account is suspended. (As mentioned in step 1). Give will include the reason the account is suspended. If the remaining balance is due to the merchant, Give will provide a time frame when the merchant should expect to receive the remaining balance. The merchant will not receive funds from fraudulent and criminal activity. Instead law enforcement will be contacted.

A copy of the evidence that the merchant submits should be forwarded to the Compliance team.

5. Rolling Reserve

For higher risk merchants, Give will implement a rolling reserve policy. During the account closure process a minimum of 10% of funds received from processing will be held in reserve. Higher risk merchants may have higher reserves required and funds will be held longer before being distributed.

6. Settle Outstanding Items

Merchant Initiated Exit

For merchant initiated closure, Give will ensure the merchant’s pending transactions such as payments, unresolved disputes, chargebacks, returns are settled and the remaining balance reviewed.

Between days 22-29, if the merchant has not responded on accounts suspended for inactivity, a second account closure notice will be sent to the merchant for merchant non fraudulent closure. Follow up with Complaint procedures is applicable.

Exit for Fraud and Exceeding Risk Appetite

If the identified risk is not resolved within the applicable grace period, fraud is confirmed, remediation is unsuccessful, or the investigation substantiates wrongdoing, the account will be prohibited from processing transactions or receiving payouts. Funds will be handled in accordance with applicable reserve requirements, settlement terms, and Give’s internal policies. The account will then proceed to formal closure as the final stage of the process.

7. Reconcile Account Balance

After outstanding items are settled and outstanding fees deducted, the merchant’s potential remaining balance will be determined. Review the twelve month trailing loss report for loss allocation. If the case is a fraudulent case, add the fraudulent activity to the 12 month trailing loss report.

Funds from suspended accounts will be transferred to a reserve account Chesapeake Bank.

8. Pre-Closure Risk Review

If the account meets escalation criteria (example: processing volume above $15,000 in the last 3 months), the Risk Team conducts a review before the account is approved for closure. All findings are documented as part of the closure decision process.

Risk Team will review and document the following:

• Presence of any open chargebacks;
• Refund patterns on recent transactions;
• Any unusual or high-volume activity in the last 3 months;
• Whether the processing volume increased significantly prior to the closure request;
• Any unresolved risk alerts that might indicate potential risk;
• Any suspicious account changes before closure (updated bank details, edited business info);
• Large withdrawal or transfer prior to initiating account closure.
• Relevant communication or past escalations that raise concern;
• The reason provided by the merchant for account closure and whether it aligns with their recent account activity;
• Escalate usual activity or activity that cannot be reasonably explained.

Once completed, the Risk Team will summarize the risk findings and provide a recommendation to the Compliance Team to support the final account closure decision.

9. Final Review

If there are no appeals or resolution, the account will be marked for closure.

10. Send Closure Confirmation

On day 30, the merchant’s account status changes to “closed” and a closure confirmation is sent to the merchant. The Merchant Agreement will be terminated. The confirmation includes final balance, refund details, the effective date of closure and contact information for post-exit inquiries.  Relevant notes will be made to the account.

Ensure the following are deactivated, access rights, logins, services, account access, tokens and API.

Exit for Fraud and Exceeding Risk Appetite

The Merchant Agreement will be terminated. If applicable, the merchant will be reported to MATCH for reasons such as confirmed fraud, severe regulatory or card brand violations, other financial crime or at the direction of the Sponsor bank.

11. Post-Closure

The post closure holding period is to ensure there is sufficient time to resolve any chargebacks, fraudulent items, or compliance reviews before releasing the remaining funds to the merchant. The holding period is based on the MCC. The minimum period is 30 days and a maximum of 540 days.  Low risk MCC holding period will be between 30–60 days. High risk MCC holding period will be up to 540 days. For fraudulent, criminal and money laundering activity, the funds will be held indefinitely. Other deciding factors include transaction history, frequency of disputes and regulatory considerations. Unresolved disputes or chargebacks are deducted from this balance.

A thank you note is and the final disbursement is made at the end of the holding period. If there are no unforeseen issues, a final statement or summary of the account activity and balance will be sent to the merchant.

If the activity is unusual, submit a suspicious activity report to Chesapeake.

Exit for Fraud

In cases of confirmed fraud, substantiated wrongdoing, significant regulatory or card network violations, other financial crimes, or upon instruction from the Sponsor Bank, funds will be withheld.

12. Retention and Recordkeeping

Merchant information, transactional and activity is stored. Note any issues encountered, compliance analysis and lessons learned for service improvement.

The information contained herein is intended to provide a general overview of the Company’s policies and procedures relating to compliance with this Policy and does not constitute legal advice or a complete description of the laws and regulations relating to this Policy. The Company has made every effort to ensure the accuracy and completeness of this Policy.  This document is intended to provide guidance to employees of Company on how to comply with applicable laws and regulations related to this Policy. Employees should consult with the Legal or Compliance Department if they have any questions about the Policy or how to comply with it. Company reserves the right to modify or update this Policy at any time without notice. Employees are responsible for reviewing the Policy on a regular basis to ensure that they are aware of any changes. This Policy applies to all employees of Company, regardless of their position or location unless stated otherwise in the Policy. Employees are responsible for complying with the Policy and for reporting any suspected violations to their respective supervisor, the Legal Department, AMLCO or respective recipient of such violation as outlined in this Policy.