Legal Agreement

Terms of Service

This Terms of Service Agreement ("Agreement") is a legal contract between you and JHD Investment Group LLC, doing business as eWallet ("eWallet," "we," "us," or "our"). Please read these terms carefully before using our services.

Effective Date: December 7, 2025Questions? Contact Legal

Important Notices

  • eWallet is not a bank. We are a registered Money Services Business (MSB).
  • Banking services are provided by our partner banks, including Chase Bank and Sunrise Banks, N.A.
  • You must be at least 18 years old and a U.S. resident to use eWallet.
  • By using eWallet, you consent to identity verification (KYC/KYB) and ongoing compliance monitoring.

Regulatory Status

JHD Investment Group LLC is registered with FinCEN as a Money Services Business.

1. Company Information

eWallet is a brand and service of JHD Investment Group LLC, a Texas limited liability company headquartered in Sugar Land, Texas.

Regulatory Identifiers

  • Legal Entity: JHD Investment Group LLC (d/b/a eWallet)
  • FinCEN MSB Registration: 31000303711381
  • LEI (Legal Entity Identifier): 254900YVEEQAGIZLBY87
  • Headquarters: 830 Julie Rivers Dr, Suite 203, Sugar Land, TX 77478

eWallet is not a bank. We are a financial technology company registered with FinCEN as a Money Services Business (MSB). All regulated banking functions are performed by our partnered banks and financial service providers. eWallet operates under applicable exemptions via our bank partners.

2. Acceptance of Terms

By creating an account, accessing, or using eWallet's services, you acknowledge that you have read, understood, and agree to be bound by this Agreement, our Privacy Policy, E-Sign Disclosure, and all applicable laws and regulations.

If you do not agree with any part of these terms, you must not create an account or use our services. Your continued use of eWallet after any changes to these terms constitutes acceptance of those changes.

This Agreement includes your consent to:

  • Receive electronic communications and disclosures
  • Identity verification (KYC) and business verification (KYB)
  • Transaction monitoring for fraud and AML purposes
  • OFAC and sanctions screening
  • Data sharing with our banking and service partners as necessary to provide services

3. Eligibility

To use eWallet services, you must meet the following requirements:

  • Age: Be at least 18 years of age
  • Residency: Be a legal resident of the United States
  • Identity: Provide accurate personal information and pass identity verification
  • Legal Capacity: Have the legal capacity to enter into binding agreements
  • Not Prohibited: Not be prohibited from using financial services under applicable law
  • Not Sanctioned: Not appear on any government sanctions or watchlists

For business accounts, your business must be legally organized in the United States, and you must have authority to bind the business to this Agreement.

4. Services Description

eWallet provides digital wallet and payment services, including:

  • Digital Wallet: Store, send, and receive funds electronically
  • Payment Processing: Send and receive payments via ACH, RTP, and internal transfers
  • Debit Card: Mastercard debit card for purchases and ATM withdrawals
  • Business Services: Invoice creation, payment collection, and payouts
  • Funding: Add funds via linked bank account or debit card
  • Withdrawals: Transfer funds to your linked bank account or debit card

eWallet acts as a technology platform that facilitates these services through our banking and service partners. We do not provide banking services directly.

5. Banking & Service Partners

eWallet partners with regulated financial institutions and service providers to deliver our services. By using eWallet, you acknowledge and agree to the following partner relationships:

5.1 Custodial Banking

Wallet funds are held in custodial accounts at partner banks, including Chase Bank, through our service provider Checkbook.io. Your funds are held separately from eWallet's operating funds in pooled custodial accounts.

5.2 Card Issuing

The eWallet Debit Card is issued by Sunrise Banks, N.A., Member FDIC, pursuant to a license from Mastercard. Card program management is provided by Onbe.

5.3 Identity Verification

  • Consumer KYC: Identity verification is performed via Plaid
  • Business KYB: Business verification is performed via Middesk

5.4 Card Funding & Tokenization

Debit card funding and card tokenization services are provided by Stripe.

We do not store raw card numbers. Card details are tokenized and stored by PCI DSS–certified processors.

5.5 Payment Processing

ACH transfers, RTP (Real-Time Payments), internal transfers, and push-to-card operations are processed through Checkbook.io.

6. Account Registration

To use eWallet services, you must create an account and provide accurate, complete, and current information. You agree to:

  • Provide truthful and accurate information during registration
  • Maintain and promptly update your account information
  • Maintain the confidentiality of your account credentials
  • Accept responsibility for all activities under your account
  • Immediately notify us of any unauthorized access or security breach
  • Not share your account credentials or allow others to access your account

We may require additional information or documentation at any time to verify your identity, comply with regulations, or assess risk.

7. Identity Verification (KYC/KYB)

As a registered Money Services Business, we are required by law to verify the identity of all users. By creating an account, you consent to:

  • Identity Verification: Providing personal information including your full legal name, date of birth, Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN), residential address, and government-issued identification
  • Document Collection: Submitting identification documents such as driver's license, passport, or state ID for verification
  • Business Verification: For business accounts, providing business registration documents, Employer Identification Number (EIN), beneficial ownership information, formation documents, and other required documentation
  • Continuous Monitoring: Ongoing verification and monitoring as required by regulation or risk assessment
  • Watchlist Screening: Screening against government sanctions lists, OFAC lists, politically exposed persons (PEP) databases, and other watchlists

Failure to complete verification or provide requested documentation may result in account limitations, suspension, or closure.

8. Wallet & Funds

8.1 Wallet Structure

Your eWallet balance represents funds held on your behalf in pooled custodial accounts at our partner banks, including Chase Bank. These funds are held separately from eWallet's operating funds.

8.2 FDIC Insurance

eWallet is not a bank and is not FDIC insured. However, funds held in your eWallet may be eligible for FDIC pass-through insurance up to $250,000 per depositor through our Program Banks, subject to applicable limits, conditions, and aggregation rules. Funds in transit may not be insured. See our FDIC Disclosure for complete details.

8.3 No Interest

Wallet balances do not earn interest. eWallet may earn interest or other revenue on aggregated customer funds held at our partner banks.

8.4 Funding Your Wallet

You may add funds to your wallet via:

  • ACH transfer from a linked bank account
  • Debit card funding (via Stripe)
  • RTP (Real-Time Payments) from supported banks
  • Receiving payments from other eWallet users

8.5 Holds and Restrictions

We may place holds on funds, restrict transactions, or freeze accounts in the following circumstances:

  • Suspected fraud or unauthorized activity
  • Pending verification or compliance review
  • Regulatory requirements or legal process
  • Disputes or chargebacks
  • Terms of Service violations
  • AML/OFAC compliance requirements

9. eWallet Debit Card

The eWallet Debit Card is issued by Sunrise Banks, N.A., Member FDIC, pursuant to a license from Mastercard.

9.1 Card Features

  • Make purchases anywhere Mastercard is accepted
  • Withdraw cash at ATMs worldwide
  • Virtual card available immediately upon approval
  • Physical card shipped upon request
  • Real-time transaction notifications
  • Card controls (lock/unlock, spending limits)

9.2 Cardholder Agreement

Your use of the eWallet Debit Card is subject to the Cardholder Agreement provided by Sunrise Banks, N.A. This agreement governs card terms, fees, dispute rights, liability limits, and other important information. See our Cardholder Agreement for details.

9.3 Card Limits

The eWallet Debit Card is subject to daily spending and ATM withdrawal limits. These limits may vary based on your verification level and account status. Current limits are displayed in your account settings.

9.4 Zero Liability Protection

Mastercard's Zero Liability policy protects you from unauthorized transactions, subject to the terms and conditions of the cardholder agreement and applicable law.

10. Transactions & Limits

10.1 Transaction Types

  • Wallet-to-Wallet: Instant transfers between eWallet users
  • Invoice Payments: Pay invoices from eWallet businesses
  • ACH Transfers: Send/receive funds to/from external bank accounts (3-5 business days)
  • Same-Day ACH: Expedited ACH transfers (same business day)
  • RTP Transfers: Real-time payments to/from supported banks
  • Card Transactions: Purchases and ATM withdrawals using your debit card
  • Push-to-Card: Instant withdrawals to eligible debit cards

10.2 Transaction Limits

Transaction limits are based on your verification tier and account type. Limits include:

  • Daily transaction limits
  • Weekly and monthly limits
  • Per-transaction maximums
  • ATM withdrawal limits

Current limits are displayed in your account. Limits may be adjusted based on verification level, account history, and risk assessment.

10.3 Transaction Finality

Wallet-to-wallet transfers and internal transactions are final and cannot be reversed once completed. ACH transactions are subject to ACH network rules and may be returned within the applicable timeframe.

11. Fees & Charges

You agree to pay all applicable fees for services as described in our Fee Schedule. Key fees include:

  • Monthly account fees (business accounts only)
  • Transaction fees for certain payment types
  • Withdrawal fees for expedited transfers
  • Card-related fees (replacement, international, ATM)
  • Dispute and chargeback fees

We may change our fees with at least 30 days' advance notice. Continued use after the effective date constitutes acceptance of fee changes. You may close your account without penalty if you do not accept new fees.

12. Compliance & Anti-Money Laundering

eWallet is registered with FinCEN as a Money Services Business (MSB #31000303711381) and maintains a comprehensive compliance program. By using our services, you acknowledge and agree to the following:

12.1 AML/BSA Compliance

  • We comply with the Bank Secrecy Act (BSA) and all applicable anti-money laundering laws
  • We maintain an AML compliance program including customer identification, transaction monitoring, and suspicious activity reporting
  • We may file Suspicious Activity Reports (SARs) as required by law

Important: We are prohibited by law from notifying you if a SAR is filed regarding your account or transactions. You agree not to disclose or discuss any SAR-related inquiries.

12.2 OFAC Sanctions

  • We screen all users and transactions against OFAC sanctions lists
  • We may block transactions or freeze accounts if sanctions matches are identified
  • You certify that you are not on any government sanctions list and are not acting on behalf of any sanctioned person or entity

12.3 Transaction Monitoring

  • All transactions are monitored for fraud and suspicious activity
  • We may delay, block, or reverse transactions that appear suspicious
  • We may request additional information to verify the legitimacy of transactions
  • Funds may be frozen or held pending investigation

12.4 Regulatory Cooperation

We reserve the right to freeze, suspend, or close accounts and report activity to law enforcement or regulatory authorities as required for compliance purposes. We are not required to provide notice when doing so would violate law or compromise an investigation.

13. Security

We implement industry-standard security measures to protect your account and data:

13.1 Payment Card Security

Card funding, tokenization, and payment processing occur within PCI DSS–compliant environments provided by our authorized third-party processors. We do not store raw card numbers.

13.2 Infrastructure Security

  • Our production systems operate in SOC 2–certified data centers provided by Vultr
  • Enforced encryption for data in transit and at rest
  • Network segmentation and audited access controls
  • Our security controls align with ISO 27001 standards

13.3 Your Security Responsibilities

  • Keep your login credentials secure and confidential
  • Enable two-factor authentication (2FA) when available
  • Do not share your account access with others
  • Report unauthorized access immediately
  • Keep your contact information current for security alerts

14. Prohibited Activities

You may not use eWallet for any illegal or prohibited purpose. Prohibited activities include:

  • Money laundering, terrorist financing, or fraud
  • Transactions involving illegal goods, services, or activities
  • Transactions with sanctioned countries, entities, or individuals
  • Circumventing our compliance, security, or verification measures
  • Providing false, misleading, or fraudulent information
  • Operating an unlicensed money services business
  • Gambling or gaming transactions (unless legally licensed)
  • Adult content or services
  • Weapons, firearms, ammunition, or explosives
  • Drugs, controlled substances, or drug paraphernalia
  • Pyramid schemes, Ponzi schemes, or multi-level marketing
  • Counterfeit goods or intellectual property violations
  • Human trafficking or exploitation
  • Sharing account credentials or allowing unauthorized access
  • Using automated systems, bots, or scrapers without permission
  • Any activity that violates applicable laws or regulations

Violation of these terms may result in immediate account termination, forfeiture of funds, and reporting to law enforcement authorities.

15. Disputes & Error Resolution

15.1 Regulation E Rights

For consumer accounts, you have rights under Regulation E (Electronic Fund Transfer Act) for unauthorized transactions and errors. If you believe there has been an error or unauthorized transaction, you must notify us within 60 days of the statement date.

15.2 Investigation Timeline

  • 10 business days: Initial investigation period
  • 45 days: Extended investigation if needed (90 days for new accounts, POS transactions, or foreign transactions)
  • Provisional credit: May be provided within 10 business days while investigating

15.3 How to Report

Report errors or unauthorized transactions immediately by:

  • Phone: 1-877-827-0995
  • Email: disputes@ewallet.app
  • In-App: Navigate to Support > Report an Issue

See our Dispute Resolution page for complete procedures.

15.4 Chargebacks

For debit card transactions, you may have additional dispute rights under Mastercard network rules. Chargeback fees may apply as described in our Fee Schedule.

16. Limitation of Liability

To the maximum extent permitted by applicable law:

  • eWallet shall not be liable for indirect, incidental, special, consequential, or punitive damages
  • eWallet shall not be liable for loss of profits, data, business opportunities, or goodwill
  • eWallet shall not be liable for damages resulting from third-party service provider failures, including banking partners, payment networks, or telecommunications providers
  • eWallet shall not be liable for damages resulting from your failure to maintain account security
  • eWallet shall not be liable for delays or failures due to circumstances beyond our reasonable control
  • eWallet shall not be liable for compliance actions taken in good faith

Our total aggregate liability for any claims arising from this Agreement shall not exceed the lesser of (a) the fees you paid to eWallet in the 12 months preceding the claim, or (b) $500.

Some jurisdictions do not allow certain limitations of liability. In such cases, our liability shall be limited to the maximum extent permitted by applicable law.

17. Termination

17.1 Termination by You

You may close your account at any time by contacting support or through your account settings. Upon closure, you must withdraw all funds within 30 days. See our Account Deletion Policy for details.

17.2 Termination by eWallet

We may suspend or terminate your account:

  • Immediately for Terms of Service violations or suspected fraud
  • Immediately for compliance or regulatory reasons
  • Immediately for AML/OFAC concerns
  • With 60 days' notice for any other reason

17.3 Effect of Termination

  • Pending transactions may be completed or cancelled
  • You remain liable for any fees or obligations incurred
  • We will return any remaining funds less applicable fees and holds
  • We may retain your data as required by law (minimum 5 years for AML purposes)
  • Provisions that by their nature should survive termination will remain in effect

18. Privacy & Data Protection

Your privacy is important to us. Our Privacy Policy explains how we collect, use, share, and protect your personal information. Key points include:

  • We collect personal, financial, device, and transaction data as necessary to provide services
  • We share data with our banking and service partners (Plaid, Middesk, Stripe, Checkbook.io, Chase Bank, Sunrise Banks/Onbe) as described in this Agreement
  • We retain data for a minimum of 5 years as required by anti-money laundering regulations
  • We implement encryption and security measures to protect your data
  • You have rights to access, correct, and in some cases delete your data (subject to legal retention requirements)

19. Changes to Terms

We may modify this Agreement at any time. When we make material changes:

  • We will provide at least 30 days' advance notice via email and/or in-app notification
  • The updated terms will be posted on this page with a new effective date
  • Your continued use after the effective date constitutes acceptance
  • If you do not agree to the changes, you may close your account without penalty before the effective date

20. Governing Law & Dispute Resolution

This Agreement is governed by the laws of the State of Texas and applicable federal law of the United States, without regard to conflict of law principles.

20.1 Arbitration Agreement

Any disputes arising from this Agreement shall be resolved through binding arbitration in accordance with the American Arbitration Association (AAA) Consumer Arbitration Rules, except where prohibited by law. Arbitration shall take place in Harris County, Texas, or another mutually agreed location.

20.2 Class Action Waiver

You agree to resolve disputes with eWallet on an individual basis. You waive the right to participate in class action lawsuits or class-wide arbitration.

20.3 Exceptions

Notwithstanding the above, either party may seek injunctive relief in any court of competent jurisdiction. Small claims court actions may also be brought in your county of residence.

21. Contact Information

For questions about this Agreement or our services:

General Support

  • Email: support@ewallet.app
  • Phone: 1-877-827-0995

Legal Department

  • Email: legal@ewallet.app

Disputes

  • Email: disputes@ewallet.app

Mailing Address

  • JHD Investment Group LLC
  • d/b/a eWallet
  • 830 Julie Rivers Dr, Suite 203
  • Sugar Land, TX 77478