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Funds held in a Wise Account are not automatically FDIC-insured; FDIC coverage is only available for USD balances in accounts that have opted into the interest feature, which sweeps funds into participating bank accounts. Wise retains all interest and earnings generated by permissible investments made with customer funds that are not in the interest feature.
This analysis describes what Wise'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
This provision establishes that the default state of a Wise Account does not carry FDIC insurance protection, and that Wise retains all investment earnings on pooled customer funds held outside the interest feature. The conditional nature of FDIC coverage requires consumers to take an affirmative opt-in action to obtain deposit insurance protection on USD balances.
The updated terms now authorize Wise to accept incoming funds via FedNow, a new instant payment service. The agreement states that FedNow transactions are processed in real time and generally cannot be canceled or reversed once completed, distinguishing them from traditional transfers that may have reversal windows. The terms also establish that Wise may decline any incoming FedNow transaction at its discretion where required for security, compliance, or operational reasons, without specifying advance notice or appeal procedures. Users receiving FedNow payments should understand that such transfers become final immediately upon completion.
View change record →Under this clause, consumers who do not opt into the interest feature hold funds that are not FDIC-insured, and any earnings generated by Wise's permissible investments of those funds accrue to Wise rather than the consumer. Consumers who opt into the interest feature have their USD balances swept into FDIC-insured accounts at participating banks.
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"Wise is Not a Bank, and your Wise Account is Not a Bank Account. Money you hold with Wise, in any currency, is not automatically insured by any deposit protection scheme, including the Federal Deposit Insurance Corporation (FDIC). Wise holds funds held by its customers in permissible investments in accordance with applicable laws. Wise owns the interest or other earnings on these investments, if any. However, although Wise is not a Bank, eligible customers that opt-in to the "interest feature" will have their United States Dollar (USD) funds held in their Wise account "swept" into a FDIC insured, interest bearing account at one or more of our participating banks.Excerpt from Wise's Terms of Use
1. REGULATORY LANDSCAPE: This provision engages FDIC regulations governing deposit insurance eligibility and pass-through coverage in sweep arrangements. The CFPB has disclosure authority over material terms of consumer financial accounts including insurance status. State money transmitter regulations governing permissible investments of customer funds are also implicated. The assertion that Wise owns investment earnings on customer funds held in permissible investments should be evaluated against applicable state money transmitter statutes, which in some jurisdictions prescribe how earnings on customer funds may be treated. 2. GOVERNANCE EXPOSURE: High. The combination of non-automatic FDIC coverage and Wise's retention of investment earnings on non-opted-in customer funds creates material consumer disclosure obligations. Failure to adequately surface the opt-in requirement at account opening and at material balance events could constitute a deceptive or misleading practice under FTC Act or CFPB authority. 3. JURISDICTION FLAGS: All US states where Wise is licensed as a money transmitter are relevant, as state permissible investment statutes vary. Delaware (Wise's state of incorporation) and states with large customer populations such as California and New York present heightened exposure. The sweep arrangement to participating banks requires identification and disclosure of those institutions and applicable coverage limits. 4. CONTRACT AND VENDOR IMPLICATIONS: The sweep arrangement with participating banks creates a vendor dependency; compliance teams should confirm that contracts with participating banks address FDIC pass-through eligibility, coverage limits per depositor, and continuity obligations. Changes to participating banks without notice to customers (as the agreement permits) create a disclosure risk. 5. COMPLIANCE CONSIDERATIONS: Disclosure documentation should clearly distinguish between opted-in and non-opted-in account states at every relevant consumer touchpoint. Data mapping should identify which customer accounts are in each state. Regulatory notifications may be required if the list of participating sweep banks changes in a manner that affects insurance coverage. The statement that Wise retains investment earnings should be reviewed against applicable state money transmitter statutes to confirm consistency.
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This provision establishes that the default state of a Wise Account does not carry FDIC insurance protection, and that Wise retains all investment earnings on pooled customer funds held outside the interest feature. The conditional nature of FDIC coverage requires consumers to take an affirmative opt-in action to obtain deposit insurance protection on USD balances.
Under this clause, consumers who do not opt into the interest feature hold funds that are not FDIC-insured, and any earnings generated by Wise's permissible investments of those funds accrue to Wise rather than the consumer. Consumers who opt into the interest feature have their USD balances swept into FDIC-insured accounts at participating banks.
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