Some of the largest insurance companies in the world "don't make money" off of premiums either, but they are multi-billion dollar organizations.

That seems either extremely generous, tremendously stupid, or frankly, a little shady.

You wouldn't happened to be owned in whole or in part by this same bank, would you? Do you receive other, unrelated back channel income from your partners in relation to Even?

(Sorry for being intrusive, but I'm trying to figure out why you would essentially throw away thousands of dollars a month in interest earnings).

Banks don't yield interest on savings, so we're not "allowing" the bank to retain anything. It's not like having money just magically procreates into more money. Banks pay interest on savings to their customers because their business model is "we get money in the form of savings, pay a little interest so people keep that money with us, and then we lend those savings to other people at higher interest. Boom, profit."

If we kept the interest yielded on savings held with Even, we would be taking money away from our customers, not from the banks. I think you might be vastly overestimating the amount of money you can make doing this, let alone the fact that it's a pretty dick thing to do.

The only way we make money is the subscription cost of using Even.

You're collecting, withholding and pooling money from users. This we know because I'm assuming your algorithm is not set to run at a loss, and when you "average" allowances you create overages by your own admission more often than not. That money is being placed in a bank account, which we also know because it's plastered all over your site.

That bank account will pay interest to the holder, because as you point out so nicely, that's exactly what banks do.

That "holder", by default, is Even. Unless of course you are setting up a bank account for each separate user, in which case the holder could be the user in trust. That seems silly though so let's just go with the fact that the money is yours and you simply redistribute it properly.

Either way, the money is given to the bank so that they can invest/use it. So either they are retaining the extra profit by not paying any interest to Even at all, which seems ridiculously stupid from your point of view, or you are in fact retaining the interest yourselves, which you aren't disclosing. If I were running this, I'd choose the latter because I like to make money. The issue I have is that you are either not aware this is happening or - more than likely - choosing to pretend that we are too stupid to understand this.

let alone the fact that it's a pretty dick thing to do.

It's not a dick thing to do at all unless you actively avoid disclosing it. You're not charging interest for loans so from the customer's point of view, it can be taken as a break even. Of course the SEC might have a different opinion on these matters than I do.

The only way we make money is the subscription cost of using Even

I have trouble understanding a business model that requires 833 customers with significant money under management to barely take in enough for a single salary. (833 * 12 == 10K) Assuming an average income of $3K per month for these users, you'd be managing upwards of $2.5MM every month! Retaining 10% of that 2.5 as "excess overage" you'd be looking at $250K in that pooled account. At 5% interest, you're either giving the bank a windfall of $12,500, or you are keeping it.

We can all do basic back of the napkin math here. There is something about what you are telling us that doesn't jive with presenting a position that you are going to be successful with income limited to $12 per month per user. You either have another source of income or you are in bad, bad shape. We're all assuming the former.

You are missing the third, and correct option: the bank is paying interest in aggregate, and we are redistributing that interest back to the individual. If I was lying about this, wouldn't I just not answer your question instead of providing written evidence of falsification?

Overall, you are assuming many things that are not correct.

Edit— one clarification worth making: currently the way we are storing money does not earn interest at all. But this will change in the near future, and when it does earn interest, we will redistribute as described above. If money you've saved with Even earns interest, you keep it.

So, YOU ARE earning interest on the savings. This is completely contrary to your earlier statement:

No, we do not earn interest on the savings.

Do you not see how someone in my shoes sees this as a little deceptive? You're middling in technicalities and details while ignoring that overall, the two descriptions create the same outcome.

we are redistributing that interest back to the individual.

Except it says the exact opposite on your website, quite clearly.

currently the way we are storing money does not earn interest at all. But this will change in the near future, and when it does earn interest, we will redistribute as described above. If money you've saved with Even earns interest, you keep it.

Just trust us.

I wish you luck going forward, but I think you are in for a world of hurt when the regulators come knocking.

Even if that unsourced figure is correct, it doesn't really address the issue: if they aren't used to deal with "I was short because my pay was lower than normal this week", Even wouldn't help. That's its a predictable, recurring expense doesn't mean that its not a recurring pattern of timeshifting a mismatch between income and expense, rather than dealing with irregular income patterns.

Even (at best) deals with irregular income patterns, but nothing else.