CA-C-000485
Cash App — Cash App Terms of Service
Entity
Date detected
April 16, 2026
Effective date
April 16, 2026
Severity
Medium
Changes
+13 sentences added · 1 sentence modified
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What Changed

Cash App added a new section called 'Cash App Credit Score' to its Terms of Service on April 16, 2026. This internal score is based solely on your activity within Cash App and is used by Block, Inc. to determine eligibility for their own products — it is not shared with lenders or outside institutions. Importantly, the terms restrict you from using this score to apply for credit elsewhere or to represent your credit standing to third parties, so it has limited use outside the app.

Why It Matters (compliance & risk perspective)

The introduction of an internal credit score means Block is now generating financial assessments of users based on their in-app behavior, which could affect access to Cash App products without users fully understanding the scoring criteria. Consumers are also explicitly prohibited from using this score outside of Cash App, limiting its utility while the methodology remains opaque.

Consumer Impact (what this means for users)

Cash App has introduced an internal 'Cash App Credit Score' based solely on your in-app activity and transactions, which Block, Inc. uses to determine eligibility for its own products. This score is not shared with lenders and will not affect your credit score at any bureau or bank. You are prohibited from using it to apply for credit or to represent your creditworthiness to third parties, so its utility is limited to understanding your Cash App activity.

Institutional Analysis (Compliance & legal intelligence)

Assessment

Cash App added a new Section XXI introducing an internal 'Cash App Credit Score' as of April 16, 2026. The score is derived exclusively from in-app data, restricted to internal eligibility determinations, and cannot be shared externally or used for credit applications. This touches FCRA (15 U.S.C. §1681 et seq.) because any internal scoring system used to determine eligibility for financial products must be assessed for whether it constitutes a 'consumer report.' Block appears to be carving this out by explicitly limiting its use and not sharing it with lenders, but compliance teams should confirm this scoring mechanism does not trigger FCRA or ECOA obligations. Action is required for any compliance team that needs to assess vendor risk around creditworthiness determinations.

Regulatory Exposure

1. Fair Credit Reporting Act (FCRA), 15 U.S.C. §1681a — The definition of 'consumer report' and 'consumer reporting agency' must be assessed. If the Cash App Credit Score is used to determine eligibility for financial products and services, it may qualify as a consumer report, triggering obligations under §1681b (permissible purposes), §1681m (adverse action notices), and §1681e (accuracy). Block's explicit limitation that the score is not shared with lenders is a deliberate attempt to stay outside FCRA's scope, but the internal use for product eligibility warrants scrutiny.

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ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-000485.

Evidence Verification

✓ Verified
Previous Version
e39e6a8e3d2b11134e61e3f8c8c4c49b125d08028027cd149dff04d9b4ea682a
April 11, 2026 06:03 UTC
✓ Verified
Current Version
87c5681082611642b1319d7862a04bc5af15c04dfff78a469d3efd1e95bc7cbd
April 16, 2026 06:01 UTC
✓ Verified
Change Detected
April 16, 2026 06:01 UTC
✓ Verified
Source Document
https://cash.app/legal/us/en-us/tos
How to Cite
ConductAtlas Policy Archive
Entity: Cash App | Document: Cash App Terms of Service | Record: CA-C-000485
Captured: 2026-04-16 06:01:48 UTC
URL: https://conductatlas.com/change/2026-04-16-cash-app-cash-app-terms-of-service-485/
Accessed: April 18, 2026

Full Changes

View complete diff →

Document Context

Document
Cash App Terms of Service
Entity
Cash App
Captured
April 16, 2026
Source URL
https://cash.app/legal/us/en-us/tos
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