App rejected - requirement that any app offering financial services must be submitted by the financial institution performing such services.

Question

uri3001 OP

Created Jun ’19

Replies 5

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Views 6.4k

Participants 4

Hello,

I've been working on an app for 4 whole months being aware of this section in Guidelines 3.2.1(iii):

Apps used for financial trading, investing, or money management should come from the financial institution performing such services or must use a public API offered by the institution in compliance with its Terms & Conditions.

My app tracks the User's bank account using PlaidAPI like many other apps, and if the account balance gets near $0, we offer users to apply with a lender which is most relevant to their financial situation. So for example if they are in Chase bank where the overdraft fee is $34 and I can connect them with a small loan that will cost less than the overdraft fee, I will do that.

Now, the app got rejected due to this comment from the reviewer:

Guideline 3.2.1(viii) of the App Store Review Guidelines requires that any app offering financial services must be submitted by the financial institution performing such services. Therefore, apps that offer loan or credit applications from multiple third-party financial institutions cannot be made available on the App Store.

However, when looking into the specific guideline itself, it mentions that lenders are allow if you are connected to them using a public API (which we are):

Original guideline: (viii) Apps used for financial trading, investing, or money management should come from the financial institution performing such services OR must use a public API offered by the institution in compliance with its Terms & Conditions.

(https://developer.apple.com/app-store/review/guidelines/#acceptable)

I sent all the documents and agreements we have with our 3rd party integrations that include T&C but still got rejected.

Anyone has an advise please?

I hate to see the app go to waste after all this work especially when their terms explicitly state that what we did should actually be OK.

Thank you for the help in advance!

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Answer 1

chuckc192000 OP

Jun ’19

You app is offering a loan so it falls under 3.2.1. It is NOT for financial trading, investing or money management so it doesn't qualify under (viii). I don't think many customers would trust a random iPhone app with their bank account information anyway, especially if the app didn't come from their bank.

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Answer 2

uri3001 OP

Jun ’19

We are providing our users with helpful alerts to monitor their bank account easily while most apps that banks offer have very basic functionality which is diffucult to set up, thats A. Now B - our user base already exists from financial blogs we have and they trust us to build a good solution for them. Now C - your answer was not helpful and not to the point at all... I asked for help not business advice on how to build trust with our users. I've been working on this for a very long time in hope to build a good product for my existing userbase and now the app is getting rejected even though the guidelines state it should pass review. I would love to get an advice if you have any otherwise...

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Answer 3

KMT OP

Jun ’19

>it mentions that lenders are allow if

I see no mention of 'lenders' in 3.2.1 viii. Remember, they get to define their guidelines, not us.

Did you appeal? What did you say in that appeal? More than one reject/appeal cycle?

About that API, since you have to pay for it, does that include promise/help to get in the store? Seems like plaid would be of more assistance than strangers on a forum when it involves their products.

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Answer 4

chuckc192000 OP

Jun ’19

Your app will probably never be accepted because it doesn't qualify for an exception under 3.2.1 (viii). You're reading something into the guidelines that doesn't exist.

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Answer 5

PBK OP

Jun ’19

I think the App Reviewer is missing the importance of differentiating between the services of the bank providing the original account and the loaners provdiing additional money. That is who needs to provide the API to fall under the (viii) allowance.You could appeal pointing out that the "financial management" in this case is the institution supplementing the balance and therefore you are using the api's of the institution providing the service.

I apologize for the earlier back-and-forth - it has nothing to do with your problem.

Good luck!

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