Legal & Privacy
FedNow Transaction Records and Data Use
If you use FedNow-enabled payment services, Circle, its financial institution partners, service providers, other relevant FedNow participants, and the Federal Reserve Banks may collect, use, retain, and disclose transaction records and related information as needed to process, administer, settle, reconcile, investigate, enforce, or otherwise support FedNow transactions.
This information may include payment instructions, transaction details, sender and recipient information, account or routing information, technical or access-log information, and related records. It may be used and disclosed for FedNow-related directory services, fraud prevention, fraud detection, fraud investigation, risk management, compliance, reporting, dispute handling, error resolution, and other purposes permitted or required by applicable law, the FedNow Service rules, or Circle’s agreements.
Where required by applicable law, you are responsible for providing any required notices and obtaining any required consents or permissions from individuals whose information you provide in connection with a FedNow transaction, including senders, recipients, authorized representatives, and other relevant individuals.
FedNow Fraud Data
Circle, its financial institution partners, service providers, FedNow participants involved in the relevant transaction, and the Federal Reserve Banks may collect, use, retain, and share information relating to actual or suspected fraud, unauthorized activity, errors, disputes, rejected or returned payments, or other risk events involving FedNow transactions.
This information may include transaction details, customer information, sender and recipient information, account or routing information, device or access information, payment instructions, and investigation records. It may be shared as reasonably necessary to prevent, detect, investigate, report, or remediate fraud, unauthorized transactions, errors, security incidents, sanctions or compliance concerns, or other potentially unlawful or harmful activity, including with the Federal Reserve Banks, relevant FedNow participants, service providers, fraud-prevention and risk-management vendors, law enforcement, regulators, and other parties where permitted or required by applicable law or FedNow Service rules.
FedNow Fees
Circle may charge fees in connection with FedNow-enabled payment services. Any applicable fees will be shown to you at the time of the transaction, set out in the applicable fee schedule, or separately agreed between you and Circle.
FedNow-related fees may include fees for sending or receiving payments, return payments, requests for payment, or other FedNow-enabled services. Fees may be charged directly to you, paid by a partner, waived, or included as part of another service fee, depending on the applicable product, transaction flow, and agreement. Circle may update applicable fees from time to time as permitted by applicable law and its agreements with you.