OK, here are some of my thoughts. This is from someone that has worked in the financial services industry, at a fairly high level, and with direct customer contact. I’ll be honest, and hopefully explain the situation and why you’re having the customer experience that’s not what you expected or experienced in the past.
Apple is not a bank. They have to partner with companies to provide financial services. In the case of Apple Cash, Apple has partnered with Green Dot Bank. Green Dot specializes in prepaid debit cards and is ideally positioned to offer services to Apple’s customer base.
US banks are highly regulated by multiple federal and state agencies. Fines are hefty, and the publicity has an adverse effect on their business and stockholders. Multiple federal regulations apply to the transactions carried out by Apple Cash services. Violation of the terms and conditions is subject to review by the bank and also federal and state regulators.
Banks are required by the Patriot Act (enacted after 9/11) to Know Your Customers, and these laws are known as KYC regulations. But it goes beyond just you, the customer. Regulations require that they “Know Your Customer’s Customer.”
Why is KYC and KYCC required? Easy, criminals need to launder money, and banks are required to assist in detecting potential money laundering schemes. The activities they turn up may be minor, but nonetheless subject to the same regulations and scrutiny that someone laundering millions of dollars is subject to. In other words, you may have received funds or transferred funds that technically constitute money laundering schemes.
Banks don’t want the fines, publicity, and closer scrutiny that these relatively innocent violations may cause. The algorithms they use leave out the emotion and compassion a first-time offender may seek and feel justified to. Banks view an offense in strict legal terms and don’t feel they need to be offering educational opportunities. Banks typically don’t provide second chances. It’s the nature of their business.
However, mistakes can be made and, as I think you’ll agree, an opportunity to appeal and have a review. The federal government created such an oversight agency after the financial crisis in 2008/2009. Congressional law created the Consumer Financial Protection Bureau (CFPB).
Enter the CFPB that is charged with insuring banks and other financial services companies follow the law and not abuse consumers. For the last 15 years or so, there was a quick and easy complaint and review process for consumers to get relief. Unfortunately, the current administration doesn’t see things that way and just within the last few days, the CFPB had the number of their employees reduced by 90% as a cost savings measure. Not trying to politicize the discussion, just bring relevant facts to light.
The staff and Green Dot are not permitted to discuss the matter with you. There is nothing on their screens to explain or discuss. The algorithm made a decision, end of discussion with the bank. In trying to do their jobs and provide customer support, they may go over information, but they have no authority or ability to change the decision. They can escalate to a supervisor, but again, no authority or ability to change the decision. The decision is just not subject to review.
You are in the process of being de-banked. Banks often refer to it as de-risking. De-banking is the closure of people's or organizations' bank accounts by banks that perceive the account holders to pose a financial, legal, regulatory, or reputational risk to the bank.
