People dependent on the platform for access to custodial funds
Cash App US customer accounts
This subject represents US Cash App customers whose account access and custodial balances are governed by the service terms and applicable regulatory duties. It is a general affected class, separate from particular accounts mentioned in Lantern reporting.
Access and restriction mechanisms
Terms updated on 26 August 2026 reserve suspension and termination discretion, risk-based transfer delays and investigative holds. Post-termination withdrawal is conditional on other terms and pending liabilities or investigations. Separate clauses address binding legal instruments and government requests. These mechanisms coexist with the CFPB order's notice and remedy obligations. A hold need not be court-ordered, and the terms do not prove that a custodian directed any particular closure.
Current pages observed 9 September 2026. Terms display effective 7 February 2024 and update 26 August 2026; individual clause/acceptance history unknown.
Current XXIII.9 permits account/access suspension or termination at any time for any reason and reasonable notification steps; AUP II permits suspension/termination without notice for reported violations. These provisions do not erase separate regulatory duties or establish actual use in a particular case.
Current pages observed 9 September 2026. Terms display effective 7 February 2024 and update 26 August 2026; individual clause/acceptance history unknown.
VI.1(e)(iii) permits risk-based transfer delays/limits and investigation holds; XXIII.11 makes post-termination withdrawal subject to company discretion and other terms, including pending liabilities/investigation. No universal release deadline, actual forfeiture or confiscation is established.
reserves responses to legal process and government requests
Current pages observed 9 September 2026. Terms display effective 7 February 2024 and update 26 August 2026; individual clause/acceptance history unknown.
XXIII.3 covers freeze/withhold/remit responses to specified binding legal instruments; VI.1(e)(iii) separately includes government requests. These coexist with discretionary risk holds; not every hold is court-ordered and no specific government instruction is acquired.
must use Cash App to access custodial balances under terms
Current pages observed 9 September 2026. Terms display effective 7 February 2024 and update 26 August 2026; individual clause/acceptance history unknown.
VI.3 says balances are separate from corporate funds and accessed through Cash App, not directly at custodial banks/brokerages. Limited agency/custody arrangement does not prove Block ownership of funds or that a custodial bank directed a closure.
Current pages observed 9 September 2026. Terms display effective 7 February 2024 and update 26 August 2026; individual clause/acceptance history unknown.
Current XXIII.9 permits account/access suspension or termination at any time for any reason and reasonable notification steps; AUP II permits suspension/termination without notice for reported violations. These provisions do not erase separate regulatory duties or establish actual use in a particular case.
Current pages observed 9 September 2026. Terms display effective 7 February 2024 and update 26 August 2026; individual clause/acceptance history unknown.
VI.1(e)(iii) permits risk-based transfer delays/limits and investigation holds; XXIII.11 makes post-termination withdrawal subject to company discretion and other terms, including pending liabilities/investigation. No universal release deadline, actual forfeiture or confiscation is established.
Current pages observed 9 September 2026. Terms display effective 7 February 2024 and update 26 August 2026; individual clause/acceptance history unknown.
XXIII.3 covers freeze/withhold/remit responses to specified binding legal instruments; VI.1(e)(iii) separately includes government requests. These coexist with discretionary risk holds; not every hold is court-ordered and no specific government instruction is acquired.
Current pages observed 9 September 2026. Terms display effective 7 February 2024 and update 26 August 2026; individual clause/acceptance history unknown.
VI.3 says balances are separate from corporate funds and accessed through Cash App, not directly at custodial banks/brokerages. Limited agency/custody arrangement does not prove Block ownership of funds or that a custodial bank directed a closure.