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Money you load onto your Revolut card is held by Lead Bank and is covered by FDIC deposit insurance up to applicable limits, but only if certain eligibility requirements are met. This is not an unconditional guarantee of coverage.
This analysis describes what Revolut'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
FDIC pass-through insurance for prepaid cards is conditional on specific requirements, including that your account must be identifiable as belonging to you on Lead Bank's records. If those conditions are not met, your funds may not be insured in the event of Lead Bank's failure.
The updated Terms of Service no longer document the Move Money Rules feature, which previously allowed users to set up automatic fund transfers across account pockets or currency exchanges based on custom conditions. The removal of this documentation means users cannot point to the terms as a reference for how this feature operates, what limits apply, or what fees may be charged. If the feature remains available in the app, its operational parameters are no longer formally described in the binding terms document.
View change record →Your funds held through Revolut at Lead Bank are potentially covered by FDIC insurance up to applicable limits, but coverage is conditional and not automatic. If Lead Bank were to fail and pass-through eligibility requirements were not met, your funds could be at risk.
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"The funds that you deposit in your Revolut Card account are held by Lead Bank and are insured by the FDIC up to applicable limits in the event of the bank's failure, if specific deposit insurance requirements are met. See FDIC-Prepaid Cards and Deposit Insurance Coverage for details.Excerpt from Revolut's Terms of Service (Superseded URL)
REGULATORY LANDSCAPE: FDIC pass-through insurance for prepaid card programs is governed by FDIC regulations and guidance on deposit insurance for prepaid cards. The FDIC requires that the underlying account be properly titled and that individual account ownership be determinable from the bank's or program manager's records. This is enforced by the FDIC as the deposit insurer and primary federal regulator of Lead Bank. GOVERNANCE EXPOSURE: Medium. The conditional nature of pass-through insurance is a disclosed risk, but the adequacy of recordkeeping by Revolut as program manager is critical to ensuring coverage eligibility. If Revolut's records are not maintained in a way that allows the FDIC to identify individual beneficial owners, insurance coverage could be denied. JURISDICTION FLAGS: FDIC insurance is a federal framework applicable uniformly across US jurisdictions. However, state banking regulators may have additional oversight over Lead Bank's prepaid card programs, and state unclaimed property laws interact with funds held after account closure. CONTRACT AND VENDOR IMPLICATIONS: Institutional clients or partners relying on the FDIC insurance representation should review the Cardholder Agreement for the specific terms under which Lead Bank holds funds and confirm that the pass-through insurance structure meets FDIC guidance for prepaid programs. The agreement's reference to 'if specific deposit insurance requirements are met' should prompt review of what those requirements are and how Revolut ensures compliance. COMPLIANCE CONSIDERATIONS: Program managers operating prepaid card programs with FDIC pass-through insurance claims should maintain current documentation of their recordkeeping practices and confirm alignment with FDIC guidance for custodial account insurance. Any material change to the Lead Bank relationship or account structure would warrant a fresh assessment of insurance eligibility.
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FDIC pass-through insurance for prepaid cards is conditional on specific requirements, including that your account must be identifiable as belonging to you on Lead Bank's records. If those conditions are not met, your funds may not be insured in the event of Lead Bank's failure.
Your funds held through Revolut at Lead Bank are potentially covered by FDIC insurance up to applicable limits, but coverage is conditional and not automatic. If Lead Bank were to fail and pass-through eligibility requirements were not met, your funds could be at risk.
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