This analysis describes what Cash App's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The provision operationalizes Cash App's role as a technology intermediary connecting users to licensed brokerage services rather than acting as a direct broker-dealer itself. This structure determines regulatory oversight, liability allocation, and which entity holds primary responsibility for investment account operations.
The updated terms introduce a new stablecoin withdrawal feature that allows Cash App users to convert USD to stablecoins and send them to external blockchain addresses. Under the revised language, users do not acquire ownership or title to stablecoins; Cash App or its partners retain full control until delivery to the specified address. Critically, the terms state that withdrawals cannot be reversed or refunded once initiated on the blockchain, and sending assets to unsupported networks or incorrect addresses will result in permanent and irreversible loss of funds. Users are solely responsible for verifying accurate withdrawal instructions and compatible network addresses before initiating transfers.
View change record →The updated terms increase the Foreign Transaction Fee from 3% to 3.25% and narrow the circumstances under which this fee is waived. Previously, users who spent $500+ monthly or received $300+ in deposits waived the entire Foreign Transaction Fee. Under the revised terms, the fee waiver now applies only to card-present (in-person) transactions, meaning online and card-not-present international purchases remain subject to the fee without a waiver path. Users making qualifying purchases or deposits still receive fee waivers, but only for in-person international card transactions through the end of the following calendar month.
View change record →The updated terms state that Cash App will discontinue its Remittance Service effective May 1, 2026. Any remittance payment still pending on or after May 1, 2026 will continue to be processed unless the sender cancels the transfer. However, any remittance payment sent via cash pickup that is not picked up within 21 days will be automatically canceled, and all remittance payments remaining in pending state on May 21, 2026 will be automatically canceled and refunded to the sender. Additionally, for California residents with Cash App Cards, the gift card cash redemption threshold was increased from $10 to $15. You can cancel pending remittance transfers before May 1, 2026 to manage the transition.
View change record →Users accessing Cash App's investment features operate under terms established by both Cash App and its broker-dealer partner, with specific requirements for account setup, trading authorization, and settlement procedures determined by the brokerage agreement. Investment transactions proceed through the partner broker-dealer's systems and regulatory framework.
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"X. Cash App Investing— Excerpt from Cash App's Cash App Terms of Service
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The provision operationalizes Cash App's role as a technology intermediary connecting users to licensed brokerage services rather than acting as a direct broker-dealer itself. This structure determines regulatory oversight, liability allocation, and which entity holds primary responsibility for investment account operations.
Users accessing Cash App's investment features operate under terms established by both Cash App and its broker-dealer partner, with specific requirements for account setup, trading authorization, and settlement procedures determined by the brokerage agreement. Investment transactions proceed through the partner broker-dealer's systems and regulatory framework.
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