PaymentsFebruary 3, 2026

Why Card Programs Are Failing and What Will Survive

Originally published in The Collateral on LinkedIn.

In recent months, a number of card programs have gone offline with little warning.

Not because users disappeared. Not because products failed. But because the infrastructure underneath them was not ready for real-world scrutiny.

This is not a downturn. It is a reset.

What is being filtered out

The issuers that treated compliance as an afterthought are being cleaned out.

Not selectively. Structurally.

For a long time, parts of the ecosystem optimized for the fastest launch, the lowest cost, and the widest promise set.

Many programs chose partners based on what sounded good in a pitch deck, not on commercial readiness.

That tradeoff is now surfacing publicly and expensively.

The lesson for builders

Programs that prioritized speed, price, or popularity alone are learning a hard truth.

Not everything promised is true. And not everything that works at launch survives contact with regulators, banks, and scale.

When infrastructure fails:

Cards stop working immediately
Users lose trust just as fast
Teams inherit problems they did not design for

These risks do not show up in feature lists. They show up in outcomes.

What actually lasts

What emerges on the other side of this correction will be fewer players, higher standards, compliance-first operating models, and more sustainable business designs.

This is not about being conservative. It is about being structurally sound.

Why starting small matters

The strongest programs do not try to do everything on day one.

They start with a narrow, well-defined use case. They prove compliance and operational discipline early. They build trust with users, banks, and regulators. They expand only once the foundation is proven.

Commercial readiness beats ambition every time.

The BCS approach

At BCS, we believe card programs should be built for longevity, not just launch.

That is why we provide:

Multitenant infrastructure with optional, vetted issuers across jurisdictions
A risk management and compliance-first framework embedded from day one
Backend infrastructure that abstracts complexity instead of pushing it onto product teams

BCS offers everything a co-branded card launch needs to engage users today, operate under scrutiny, and build a program that sticks while remaining expandable as products and markets evolve.

Our philosophy is deliberate. Spend first. Expand second.

That is why we focus initially on spend use cases and then evolve into loan-to-spend products only once compliance, risk, and operational layers are ready.

The real decision builders face

Choosing a partner should not be dictated by the fastest solution, the cheapest offer, or the most popular name.

It should be dictated by who understands the industry inside out, who has the structural parts in place, who expects scrutiny instead of reacting to it, and who will still be there when the rules tighten again.

A final thought

This reset is not over, but its direction is clear.

If you are building for the long term, choose partners who are too.

Partners who invest in compliance readiness, risk management, and infrastructure before they are forced to.

That is how card programs stop breaking and start lasting.

Back to the Journal Read on LinkedIn

BCS Global Holdings, Inc. — Delaware C-Corp·Last Updated: March 31, 2026

Contents

Introduction

BCS Global Holdings, Inc. ("BCS," "we," "us," or "our") is a technology company that provides a non-custodial software platform (the "Platform") enabling users to access and interact with services offered by independent third-party providers. BCS is fully non-custodial — we do not request, store, or have access to your private keys, seed phrases, or wallet balances beyond publicly available on-chain data. BCS acts solely as a technological conduit and does not offer, hold, or transmit funds, crypto-assets, or provide any financial, custodial, or regulated services.

These Terms of Service ("Terms") govern your access to and use of the Platform, including any related websites, applications, APIs, and services provided by BCS. By accessing or using the Platform, you agree to be bound by these Terms. If you do not agree to these Terms, you must not access or use the Platform.

1. Eligibility

1.1 Age and Capacity

You must be at least 18 years of age and have full legal capacity to enter into binding contracts in your jurisdiction to use the Platform. By using the Platform, you represent and warrant that you meet these requirements.

1.2 Geographic Restrictions

The Platform is not available to residents of the following U.S. states: Hawaii, New York, or any state where we determine that offering the Platform would require licensing or regulatory approvals that we have not obtained. The Platform is not available to residents of any country subject to U.S. government sanctions or embargoes, including but not limited to Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions of Ukraine. By using the Platform, you represent and warrant that you are not a resident of any restricted jurisdiction.

1.3 Business Users

If you are using the Platform on behalf of a business or other legal entity, you represent and warrant that you have the authority to bind that entity to these Terms, and in that case "you" and "your" will refer to that entity.

2. Platform Description and Third-Party Providers

2.1 BCS Role

BCS provides a software interface through which you can access services offered by independent third-party providers, including card program managers, issuing banks, digital asset lenders, decentralized finance protocols, and wallet infrastructure providers. BCS is not a bank, lender, money services business, or broker-dealer. BCS does not provide financial, investment, tax, or legal advice.

2.2 Third-Party Providers

The following independent third-party providers offer services through the Platform: (a) Card Partners: a licensed card program manager and its issuing bank partner(s) that issue, manage, and process your card account and transactions. Your card account is subject to a separate Cardholder Agreement with the issuing bank; (b) Lending/DeFi Protocols: decentralized finance protocols and/or third-party lending platforms through which digital asset-backed credit may be arranged. These protocols operate autonomously on public blockchain networks and are not controlled by BCS; (c) Wallet Infrastructure Provider: a third-party non-custodial wallet provider that provisions and manages your digital asset wallet. BCS does not hold your private keys; (d) Identity Verification Provider: a third-party KYC/AML verification service; and (e) Digital Asset Conversion Provider: third-party providers that facilitate conversion of digital assets. Each Third-Party Provider operates independently under its own terms of service, privacy policy, and regulatory framework. You are responsible for reviewing and accepting the terms of each Third-Party Provider whose services you use through the Platform. BCS makes no representations or warranties regarding the availability, reliability, security, or performance of any Third-Party Provider and shall not be liable for any losses arising from Third-Party Provider failures, delays, errors, or disruptions.

3. Account Registration and Verification

3.1 Account Creation

You must create an account and provide accurate, current, and complete information. You agree to update your information promptly if it changes.

3.2 Identity Verification

In compliance with applicable anti-money laundering and know-your-customer laws and regulations, identity verification is required before you can use certain services. Verification may be conducted by BCS, our Card Partners, or other Third-Party Providers as applicable. You agree to provide: (a) a valid government-issued photo identification; (b) proof of residency; (c) a government-issued identification number (such as a Social Security Number, tax identification number, or equivalent in your jurisdiction); and (d) any additional documentation reasonably requested by BCS or its Third-Party Providers. You consent to BCS sharing your information with Third-Party Providers for verification purposes.

3.3 Account Security

You are responsible for maintaining the confidentiality of your account credentials and for all activity that occurs under your account. You agree to notify us immediately of any unauthorized use of your account. BCS shall not be liable for any loss arising from your failure to maintain account security.

3.4 Non-Custodial Digital Wallet

As part of account creation, a non-custodial digital wallet is provisioned for you through an independent third-party wallet infrastructure provider ("Wallet Provider"). Your wallet is secured by cryptographic keys that are generated and stored within the Wallet Provider's secure infrastructure. BCS does not have access to, and cannot recover, your private keys. You acknowledge that: (a) Your wallet is non-custodial — you retain sole ownership and control of all digital assets held in your wallet at all times; (b) BCS cannot access, freeze, or seize the contents of your wallet, except to the extent that BCS may restrict your access to the Platform interface; (c) If you lose access to your wallet credentials, BCS may not be able to restore access to your digital assets; (d) Your use of the wallet is subject to the Wallet Provider's terms of service, which you must separately review and accept; and (e) The Wallet Provider may use smart contract technology to facilitate your interactions with DeFi Protocols. Such technology does not transfer ownership or control of your assets to BCS.

4. Digital Asset Transactions

4.1 Supported Assets

The Platform currently supports Bitcoin (BTC). We may add or remove supported assets at our discretion with prior notice.

4.2 Transaction Processing

Digital asset transactions are processed through third-party service providers. BCS coordinates and routes your transactions but does not execute conversions as a principal or counterparty. We do not guarantee the availability, speed, or finality of any transaction, or the availability of any specific exchange rate.

4.3 Transaction Limits

Your account may be subject to daily, weekly, or monthly transaction limits based on your verification level, account history, and other factors.

4.4 Irreversibility

Blockchain transactions are irreversible. Once you initiate a digital asset transaction, it cannot be canceled or reversed.

4.5 Unauthorized Transactions

If you believe your Card has been lost, stolen, or that an unauthorized transaction has been made, you must immediately notify the card-issuing bank using the contact information in your Cardholder Agreement. Your rights and liability regarding unauthorized card transactions are governed solely by applicable law and your Cardholder Agreement with the issuing bank. BCS is not the card issuer, does not adjudicate card disputes, and has no liability for unauthorized card transactions. For unauthorized access to your BCS Platform account, notify BCS immediately at hello@bitcoincredit.services. You are liable for all activity on your account until you notify us.

5. Risks

5.1 Digital Asset Risk

Digital assets are highly volatile and speculative. You may lose some or all of the value of your digital assets. BCS does not guarantee any particular rate of return or the preservation of value.

5.2 Technology Risk

The Platform relies on blockchain technology, third-party services, and internet connectivity. Service interruptions may occur. BCS does not guarantee continuous, uninterrupted, or error-free availability of the Platform.

5.3 Regulatory Risk

The regulatory environment for digital assets is evolving. Changes in law may require us to modify or discontinue services.

5.4 Tax Risk

You are solely responsible for your tax obligations. BCS does not provide tax, legal, investment, or financial advice.

5.5 DeFi Protocol Risk

If you use the Platform to interact with DeFi Protocols, your collateral may be liquidated by the Protocol, and you may lose some or all of your posted digital assets. Lending terms, interest rates, collateral requirements, and liquidation rules are determined solely by the Protocol.

5.6 No Fiduciary Duty

BCS is not your fiduciary, advisor, or agent. No communication or information provided by BCS shall be considered investment advice, financial advice, trading advice, legal advice, or tax advice. You alone are responsible for determining whether any transaction or strategy is appropriate for you based on your personal objectives, financial circumstances, and risk tolerance.

5.8 No Warranty

THE PLATFORM IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. BCS DOES NOT WARRANT THAT THE PLATFORM WILL BE UNINTERRUPTED, SECURE, OR FREE OF ERRORS, VIRUSES, OR OTHER HARMFUL COMPONENTS. NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED FROM BCS SHALL CREATE ANY WARRANTY NOT EXPRESSLY STATED IN THESE TERMS.

6. Intellectual Property

The Platform, including its content, features, and functionality, is owned by BCS and is protected by copyright, trademark, patent, trade secret, and other intellectual property laws. You are granted a limited, non-exclusive, non-transferable, revocable license to access and use the Platform for your personal or internal business purposes. You may not copy, modify, create derivative works of, distribute, sell, or otherwise exploit the Platform or its content without our prior written consent.

7. Prohibited Activities

You agree not to use the Platform to: violate any applicable law or regulation; engage in money laundering, terrorist financing, or other financial crimes; circumvent, disable, or otherwise interfere with security features of the Platform; use automated tools, bots, scrapers, or crawlers without our prior written consent; impersonate any person or entity or misrepresent your affiliation with a person or entity; upload, transmit, or distribute any malware, viruses, or other harmful code; conduct any activity that could damage, disable, or impair the Platform or BCS's infrastructure; or engage in any transaction involving the proceeds of illegal activity.

8. Fees

BCS may charge fees for certain services, including but not limited to account maintenance, digital asset transactions, card usage, and credit line services. All applicable fees are described in the Fee Schedule, which is incorporated by reference into these Terms. BCS reserves the right to change its fees at any time with prior notice. Continued use of the Platform after a fee change constitutes your acceptance of the new fees.

9. Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, BCS AND ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AND AGENTS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES, INCLUDING BUT NOT LIMITED TO LOSS OF PROFITS, REVENUE, DATA, BUSINESS, OR GOODWILL, ARISING OUT OF OR IN CONNECTION WITH YOUR USE OF THE PLATFORM, EVEN IF BCS HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IN NO EVENT SHALL BCS'S TOTAL LIABILITY TO YOU FOR ALL CLAIMS EXCEED THE GREATER OF (A) THE TOTAL FEES YOU PAID TO BCS IN THE TWELVE (12) MONTHS PRIOR TO THE EVENT GIVING RISE TO THE LIABILITY, OR (B) ONE HUNDRED DOLLARS ($100).

10. Indemnification

You agree to indemnify, defend, and hold harmless BCS and its affiliates, officers, directors, employees, and agents from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys' fees) arising out of or relating to your violation of these Terms or your use of the Platform, including but not limited to your violation of any applicable law, your infringement of any third-party rights, or any content you submit to the Platform.

11. Dispute Resolution

11.1 Arbitration Agreement

PLEASE READ THIS SECTION CAREFULLY. IT AFFECTS YOUR LEGAL RIGHTS, INCLUDING YOUR RIGHT TO FILE A LAWSUIT IN COURT. Any dispute, claim, or controversy arising out of or relating to these Terms or your use of the Platform that is not resolved informally shall be resolved by binding individual arbitration administered by JAMS under its Streamlined Arbitration Rules and Procedures, except as modified by this Section. The arbitration shall be conducted in Miami, Florida, or another mutually agreed location. The arbitrator's decision shall be final and binding.

11.2 Class Action Waiver

YOU AND BCS AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING. If this class action waiver is found to be unenforceable, then the entire Arbitration Agreement shall be null and void.

11.3 Governing Law

These Terms shall be governed by the laws of the State of Delaware, without regard to its conflict of law provisions, except to the extent that applicable federal law applies.

12. Termination and Suspension

12.1 Termination by BCS

BCS may suspend or terminate your access to the Platform at any time, with or without notice, for any reason, including but not limited to your violation of these Terms, suspicious or fraudulent activity, regulatory requirements, or business decisions.

12.2 Termination by You

You may close your account at any time by contacting us. Account closure is subject to the resolution of any outstanding obligations, including repayment of any outstanding credit balance and the orderly return of any remaining collateral.

12.3 Effect of Termination

Upon termination, your right to use the Platform will immediately cease. BCS will close your account and return any remaining collateral in accordance with applicable law and the terms of the applicable Third-Party Providers.

12.5 Set-Off

BCS may, without prior notice, set off any amounts you owe to BCS under these Terms against any amounts BCS owes to you, including any card balance, collateral proceeds, or other funds.

13. Communications

13.1 Electronic Communications

By creating an account, you consent to receive all communications from BCS electronically, including account statements, notices, disclosures, and other information required by law. Your consent to electronic communications is governed by our Electronic Communications Consent Agreement, which is incorporated into these Terms by reference. You may withdraw your consent to electronic communications at any time by contacting us, but withdrawal may result in the closure of your account.

13.2 Communication Methods

You consent to receive communications from BCS through any lawful means, including email, push notifications, text messages (SMS/MMS), telephone calls (including prerecorded or autodialed calls), and in-app notifications, at any telephone number or email address you provide to us. Standard message and data rates may apply. You may opt out of promotional communications at any time, but you may not opt out of transactional or legally required communications while maintaining an active account.

13.3 TCPA Consent

By providing your telephone number to BCS, you expressly consent to receive autodialed and/or prerecorded calls and text messages from BCS or its agents at the telephone number(s) you provide, for purposes including account servicing, transaction alerts, fraud prevention, and marketing. This consent is not a condition of purchasing any goods or services. You may revoke this consent at any time by contacting us.

14. Modifications

BCS may add, delete, or change any provision of these Terms at any time, at its sole discretion. Changes may reflect, among other things, changes in technology, applicable law or regulation, or business practices. We will post the updated Terms on the Platform and may notify you by email or in-app notification, but we are not required to provide individualized notice of every change. Only an authorized officer of BCS may modify these Terms, and any modification must be in writing. Your continued use of the Platform after the posting of any modification constitutes your acceptance of the revised Terms. If you do not agree with any modification, your sole and exclusive remedy is to close your account.

17. General Provisions

17.1 Assignment

You may not assign or transfer these Terms, or any rights or obligations hereunder, without BCS's prior written consent. BCS may assign these Terms, in whole or in part, without restriction, including in connection with a merger, acquisition, corporate reorganization, or sale of all or substantially all of its assets. Any attempted assignment in violation of this section shall be void.

17.2 Severability

If any provision of these Terms is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, the remaining provisions shall continue in full force and effect.

17.3 Entire Agreement

These Terms, together with the Privacy Policy, Risk Disclosures, Fee Schedule, Electronic Communications Consent, Cardholder Agreement, and any other documents expressly incorporated by reference, constitute the entire agreement between you and BCS with respect to the subject matter hereof and supersede all prior or contemporaneous agreements, proposals, or representations, whether written or oral.

17.6 Notices

All notices from BCS to you will be sent to the email address associated with your account. You are responsible for keeping your email address current. Notices from you to BCS regarding legal matters must be sent to legal@bitcoincreditservices.com.

17.8 Survival

Sections 5 (Risks), 6 (IP), 7 (Prohibited Activities), 9 (Limitation of Liability), 10 (Indemnification), 11 (Dispute Resolution), 12.5 (Set-Off), and 17 (General Provisions) shall survive termination or expiration of these Terms.

17.9 Statute of Limitations

Any claim arising out of or relating to these Terms must be filed within one (1) year after the cause of action accrues, or the claim is permanently barred.

18. Copyright Infringement / DMCA Notice

If you believe that content on the Platform infringes your copyright, you may submit a notice pursuant to the Digital Millennium Copyright Act (17 U.S.C. § 512) to our designated agent at hello@bitcoincredit.services. Your notice must include: (a) a description of the copyrighted work; (b) identification of the infringing material; (c) your contact information; (d) a statement of good faith belief that the use is unauthorized; (e) a statement under penalty of perjury that the information is accurate and you are the owner or authorized to act on behalf of the owner; and (f) your physical or electronic signature.