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BankMobile Disbursements Tier One (T1) Arrangement Due Diligence Attestation for the period July 1, 2020 – June 30, 2022

In accordance with section 34 CFR §668.164(e)(2)(x)(A)-(B) of the U.S. Department of Education’s amended Cash Management regulations published in the Federal Register on October 30, 2015, your institution is required to conduct and document reasonable due diligence every two (2) years. The Secretary defines this requirement as met in two ways: (i) the institution must conduct due diligence every two (2) years to determine whether the fees associated with the financial account offered under a T1 Arrangement are “considered as a whole, consistent with or below prevailing market rates”; and (ii) the contract governing the T1 Arrangement includes a provision for termination due to student complaints or if the institution determines the fees associated with the financial account offered under a T1 Arrangement “are not consistent with or are higher than prevailing market rates”.


Suggested Items to Review

As it relates to requirement (i) noted above, in addition to the institution conducting its own reasonable due diligence related to the student financial account offered by us under the T1 arrangement, we recommend that your institution review the documentation listed below to “ascertain whether the fees imposed under the T1 arrangement are, considered as a whole, consistent with or below prevailing market rates”:


  1. Review the “Mean and Median Account Cost Disclosure” associated with the student financial account offered by us under the T1 arrangement. Please note that the fee information in this disclosure is provided on an annual basis. This is posted to your institution’s unique document library URL which can be found in bankmobileadminsupport.com under Client Profile and select School Contract Page.
  2. Review CFPB’s “Data Point: Checking Account Overdraft” report, including information about average monthly checking account fees as part of our due diligence.
  3. Review our Fee Comparison Chart, which compares the BankMobile Vibe Checking Account fees with the three (3) most prominent checking accounts used by students to receive their financial aid credit balances.
  • Due Diligence Attestation Submission Form

    As it relates to item (ii), the required contractual language set forth in this provision is included in our standard contract or any applicable amendment to the agreement. This provision is generally listed in the “Institution Obligations” section of Exhibit B to your services agreement.