Partner-managed

in cross river's partner managed model, partners are responsible for managing the card’s lifecycle and communicating relevant updates to cross river via daily reporting there are a series of requirements that the partner must meet before a card can be issued to a customer partners are required to ensure that the customer profile is created the customer passes the required ofac/pep screenings the customer’s card is associated with their cos customer record using the unique card token these steps are required to ensure cross river can conduct oversight of the card program the customer is created, that they pass the required ofac/pep screenings and that a card associated to their cos customer record by way of providing a unique card token these steps are critical to ensure cross river can conduct transaction monitoring to meet our compliance obligations detailed requirements requirement description 1 load customer data cross river performs global ofac/pep screens in our system (cos) at the time of onboarding and regularly after that 2 add id details cross river receives files from processors and from the networks with tokenized card numbers the processor uses the tokenized card numbers as unique identifiers for each cardholder to match cards with accounts, we need this unique identifier to be added to the cardholder’s cos customer record cross river expects that whenever a new card token is generated, you update this cos customer record it makes no difference if the card is new or reissued 3 for commercial card partners associate beneficial owner cross river requires commercial card partners to create both business and cardholder customer records in cos use the customer management call to update the cos customer record in the partner managed model, when the processor creates the card in their system, we need the partner to create a customer in cos card lifecycle and customer controls partners are responsible for defining and managing the full customer card experience through their processor \[1], including card issuance card activation card suspension and unsuspension administrative blocks card closure and replacement \[1] this is subject to due diligence review and at in the sole discretion of cross river