{
  "model": "grayson-1",
  "state": {
    "platform": {
      "who_we_are": "A consumer fintech app: a spending account held at our partner bank, a Visa debit card, instant transfers to and from linked debit cards and bank accounts, and a rewards program.",
      "review_queue": "Rewards risk review. A reward goes to this queue instead of being paid when a rewards rule fires on it; analysts pay, keep holding, deny, or deny and close.",
      "customer_base": "About 1.9 million funded accounts; 41,000 rewards paid in September 2026."
    },
    "promotion_terms": {
      "name": "Give $50, Get $50 (referral program, terms revised 2026-03-01)",
      "reward": "$50 to the new customer (referee) and $50 to the customer who referred them (referrer)",
      "how_to_qualify": "The referee opens an account through the referrer's link or code, verifies their identity, and receives qualifying direct deposits totaling at least $200 within 45 days of opening.",
      "qualifying_direct_deposit": "An ACH credit from an employer, payroll provider or government benefits payer. Transfers from your own accounts at other institutions, P2P payments, merchant payouts and cash loads don't qualify.",
      "limits": "One account and one sign-up or referral reward per person, for new customers only. A referrer can earn up to 10 referral rewards ($500) per calendar year. You can't refer yourself or open accounts for other people.",
      "timing": "Rewards are credited within 5 business days after the qualifying deposit posts, unless held for review.",
      "our_rights": "We may withhold or reverse a reward, and close accounts under the account agreement, if we find self-referral, multiple accounts, fraudulent or staged qualifying activity, or other abuse of these terms."
    },
    "program_baselines": {
      "referee_rewards_paid": 118400,
      "median_days_open_to_first_qualifying_deposit": 12,
      "referees_with_debit_card_purchases_in_first_30_days_pct": 81,
      "referees_moving_over_90pct_of_first_deposit_out_within_24h_pct": 9,
      "referees_sharing_home_address_with_referrer_pct": 7,
      "of_those_sharing_an_address_paid_after_review_pct": 91,
      "referrers_with_5_or_more_referrals_in_30_days_pct": 0.4,
      "held_referral_rewards_confirmed_as_abuse_pct": 23
    },
    "legend": {
      "ach": "SEC code PPD = consumer credit or debit originated by a company (payroll and benefits use it); company_name and entry_description are the originator's fields (16 and 10 characters); individual_name is the receiver's name as the originator sent it",
      "device_check": "From our device intelligence vendor at each session: device_id is a hardware-level fingerprint that survives app reinstalls; emulator, app_cloner, rooted and mock_location are detections with confidence; accounts_on_device counts our accounts seen on the same device_id",
      "ip_check": "From our IP intelligence vendor: connection type, ISP, geolocation and proxy score (0 to 100, higher means more likely a proxy, VPN or hosting network)",
      "rewards_risk_score": "Our rewards risk model, 0 to 100; rewards at 60 or above are held automatically"
    },
    "account": {
      "account": "x2061",
      "name": "Tavon Mills",
      "opened": "2026-09-30T03:12:41Z",
      "status": "Open; reward held",
      "acquisition": "Referral link from account x4836 (Derrick Sandoval, R1)",
      "stated_occupation": "Warehouse associate",
      "stated_employer": "Not asked at sign-up",
      "date_of_birth": "1998-04-17",
      "address": "Apt 14C, Westglen Pointe Apartments, Houston TX 77063",
      "identity_verification": {
        "method": "Database verification (no document or selfie required for accounts under our limits)",
        "result": "Pass: name, date of birth and SSN found together in credit-header records",
        "detail": "SSN first seen with this name in 2016; thin file (one closed student loan, one collection); the identity's address history is in Shreveport and Baton Rouge, LA, with no Houston address; the Westglen Pointe address doesn't match the identity"
      },
      "email": {
        "address": "tmills.0929@example.com",
        "check": "Free webmail; first seen anywhere 2026-09-28; no social or commerce history; name matches"
      },
      "phone": {
        "number": "(713) 555-0161",
        "check": "Non-fixed VoIP number; first seen 2026-09-27; not linked to the name in carrier records"
      },
      "signup_device": {
        "device_id": "dfp_7c21e09a4b",
        "reported_as": "Android 13, Google Pixel 7",
        "emulator": "Detected (high confidence): no telephony hardware, sensor readings constant",
        "app_cloner": "Detected: app running in a parallel-space container",
        "rooted": "Yes",
        "mock_location": "On; GPS reported Houston TX",
        "device_time_zone": "UTC",
        "accounts_on_device": "7 at sign-up, counting this one and R1"
      },
      "signup_ip": {
        "ip": "203.0.113.84",
        "check": "Residential proxy suspected, proxy score 92; geolocated Dallas TX; this IP was used for 6 other sign-ups on our app in the last 30 days"
      }
    },
    "devices": [
      {
        "device_id": "dfp_7c21e09a4b",
        "first_seen": "2026-09-08T02:41:10Z",
        "last_seen": "2026-10-06T14:10:47Z",
        "detections": "Emulator, app cloner, rooted, mock location",
        "accounts_on_device": "This account, R1 x4836 (since 2026-09-08) and 7 other referees of R1 and R2: x4776 Alexis Lowe (opened 2026-09-08); x3994 Malik Grant (opened 2026-09-10); x1284 Destiny Kirby (opened 2026-09-16); x8431 Roderick Pace (opened 2026-09-24); x3244 Kiara Toler (opened 2026-09-25); x9024 Tasha Quarles (opened 2026-10-03); x9092 Quentin Yates (opened 2026-10-04)"
      },
      {
        "device_id": "dfp_a93f10c2d7 and dfp_e5b8812f03",
        "first_seen": "2026-09-11T03:02:51Z",
        "last_seen": "2026-10-06T13:58:20Z",
        "detections": "Emulator, app cloner, rooted, mock location",
        "accounts_on_device": "Not seen on this account; together they opened 7 other referees of R1 and R2, and dfp_a93f10c2d7 logs in to R2"
      }
    ],
    "sessions_and_events": {
      "columns": [
        "ts",
        "event",
        "device_id",
        "ip",
        "detail"
      ],
      "rows": [
        [
          "2026-09-30T03:06:41Z",
          "Referral link opened",
          "dfp_7c21e09a4b",
          "203.0.113.84",
          "Link from R1 (Derrick Sandoval), opened in the app's sign-up flow; no install attribution from an ad or store page"
        ],
        [
          "2026-09-30T03:12:41Z",
          "Account opened",
          "dfp_7c21e09a4b",
          "203.0.113.84",
          "Sign-up form completed in 41 seconds; name, date of birth, SSN and address pasted; identity verification passed"
        ],
        [
          "2026-09-30T03:14:51Z",
          "Debit card ordered",
          "dfp_7c21e09a4b",
          "203.0.113.84",
          "Physical card mailed to the Westglen Pointe address; virtual card issued"
        ],
        [
          "2026-09-30T05:31:05Z",
          "Login",
          "dfp_7c21e09a4b",
          "203.0.113.19",
          "Viewed the referral offer page and the direct deposit form"
        ],
        [
          "2026-09-30T05:33:52Z",
          "Direct deposit form downloaded",
          "dfp_7c21e09a4b",
          "203.0.113.19",
          "Pre-filled direct deposit form with our routing and account number"
        ],
        [
          "2026-10-03T02:04:11Z",
          "Login",
          "dfp_7c21e09a4b",
          "203.0.113.140",
          "Viewed balance"
        ],
        [
          "2026-10-03T02:05:40Z",
          "Payout card added",
          "dfp_7c21e09a4b",
          "203.0.113.140",
          "Debit card x8812 added for instant transfers; $0.00 verification approved; card issuer is a prepaid program at another bank, which doesn't support a name check"
        ],
        [
          "2026-10-06T04:48:02Z",
          "Login",
          "dfp_7c21e09a4b",
          "203.0.113.140",
          "Viewed balance"
        ],
        [
          "2026-10-06T14:07:20Z",
          "Login",
          "dfp_7c21e09a4b",
          "203.0.113.77",
          "Opened from a push notification 'Your direct deposit has arrived'"
        ],
        [
          "2026-10-06T14:09:58Z",
          "Instant transfer",
          "dfp_7c21e09a4b",
          "203.0.113.77",
          "$209.21 to card x8812 (the full balance less the fee)"
        ],
        [
          "2026-10-06T14:10:47Z",
          "Login",
          "dfp_7c21e09a4b",
          "203.0.113.77",
          "Viewed the rewards page: 'Your $50 is on its way'"
        ]
      ]
    },
    "funding_and_payout_methods": [
      {
        "method": "Debit card x8812 (instant transfers out)",
        "added": "2026-10-02",
        "issuer": "Prepaid card program at another bank; name check not supported",
        "used_on_our_platform": "Added as an instant-transfer destination on 12 of our accounts under 12 different names since 2026-09-12: R1 and 11 of the referees below, this account included; $3,126.09 pushed to it in total; it has never funded any of them"
      },
      {
        "method": "No external bank account linked",
        "added": null,
        "issuer": null,
        "used_on_our_platform": null
      }
    ],
    "instant_transfers_to_card_x8812": {
      "note": "Every instant transfer to card x8812 from any of our accounts",
      "columns": [
        "ts",
        "account",
        "name",
        "amount_usd",
        "what_was_sent"
      ],
      "rows": [
        [
          "2026-09-11T15:52:00Z",
          "x4776",
          "Alexis Lowe",
          236.4,
          "qualifying deposit, full balance"
        ],
        [
          "2026-09-12T12:09:41Z",
          "x4836",
          "Derrick Sandoval (R1)",
          49.25,
          "referrer reward"
        ],
        [
          "2026-09-12T15:49:47Z",
          "x4776",
          "Alexis Lowe",
          49.25,
          "referee reward"
        ],
        [
          "2026-09-15T13:47:21Z",
          "x4836",
          "Derrick Sandoval (R1)",
          49.25,
          "referrer reward"
        ],
        [
          "2026-09-15T15:13:10Z",
          "x7375",
          "Isaiah Hardy",
          236.4,
          "qualifying deposit, full balance"
        ],
        [
          "2026-09-16T16:18:45Z",
          "x7375",
          "Isaiah Hardy",
          49.25,
          "referee reward"
        ],
        [
          "2026-09-17T15:56:55Z",
          "x9627",
          "Brianna Foster",
          222.12,
          "qualifying deposit, full balance"
        ],
        [
          "2026-09-18T13:37:47Z",
          "x9627",
          "Brianna Foster",
          49.25,
          "referee reward"
        ],
        [
          "2026-09-18T14:43:34Z",
          "x4836",
          "Derrick Sandoval (R1)",
          49.25,
          "referrer reward"
        ],
        [
          "2026-09-19T12:50:08Z",
          "x4836",
          "Derrick Sandoval (R1)",
          49.25,
          "referrer reward"
        ],
        [
          "2026-09-21T14:50:37Z",
          "x1284",
          "Destiny Kirby",
          236.4,
          "qualifying deposit, full balance"
        ],
        [
          "2026-09-21T15:31:54Z",
          "x7590",
          "Imani Vance",
          209.21,
          "qualifying deposit, full balance"
        ],
        [
          "2026-09-22T12:47:15Z",
          "x4836",
          "Derrick Sandoval (R1)",
          49.25,
          "referrer reward"
        ],
        [
          "2026-09-22T15:46:09Z",
          "x7590",
          "Imani Vance",
          49.25,
          "referee reward"
        ],
        [
          "2026-09-22T16:47:10Z",
          "x1284",
          "Destiny Kirby",
          49.25,
          "referee reward"
        ],
        [
          "2026-09-24T13:26:30Z",
          "x4836",
          "Derrick Sandoval (R1)",
          49.25,
          "referrer reward"
        ],
        [
          "2026-09-24T13:51:27Z",
          "x2013",
          "Nia Fowler",
          197,
          "qualifying deposit, full balance"
        ],
        [
          "2026-09-25T13:05:53Z",
          "x2013",
          "Nia Fowler",
          49.25,
          "referee reward"
        ],
        [
          "2026-09-25T14:30:02Z",
          "x8188",
          "Cedric Ingram",
          197,
          "qualifying deposit, full balance"
        ],
        [
          "2026-09-26T14:02:33Z",
          "x8188",
          "Cedric Ingram",
          49.25,
          "referee reward"
        ],
        [
          "2026-09-26T14:14:22Z",
          "x4836",
          "Derrick Sandoval (R1)",
          49.25,
          "referrer reward"
        ],
        [
          "2026-09-29T12:06:03Z",
          "x4836",
          "Derrick Sandoval (R1)",
          49.25,
          "referrer reward"
        ],
        [
          "2026-09-29T14:28:54Z",
          "x3244",
          "Kiara Toler",
          227.54,
          "qualifying deposit, full balance"
        ],
        [
          "2026-10-06T13:25:30Z",
          "x9024",
          "Tasha Quarles",
          209.21,
          "qualifying deposit, full balance"
        ],
        [
          "2026-10-06T14:09:58Z",
          "x2061",
          "Tavon Mills",
          209.21,
          "qualifying deposit, full balance"
        ],
        [
          "2026-10-06T15:15:13Z",
          "x6540",
          "Keisha Odom",
          206.85,
          "qualifying deposit, full balance"
        ]
      ]
    },
    "transactions_since_open": {
      "note": "Every posted item since the account opened on 2026-09-29; amounts signed (debits negative)",
      "columns": [
        "ts",
        "type",
        "amount_usd",
        "balance_usd",
        "description",
        "detail"
      ],
      "rows": [
        [
          "2026-10-06T14:02:17Z",
          "ach_credit",
          212.4,
          212.4,
          "BRISKPAY INC DIRDEP",
          "SEC PPD; company_name BRISKPAY INC; entry_description DIRDEP; company_id 18xxxxx922; individual_name TAVON MILLS"
        ],
        [
          "2026-10-06T14:09:58Z",
          "instant_transfer_out",
          -209.21,
          3.19,
          "Instant transfer to card x8812",
          "push to debit card; arrived 2026-10-06T14:10:03Z"
        ],
        [
          "2026-10-06T14:09:58Z",
          "fee",
          -3.19,
          0,
          "Instant transfer fee",
          "1.5%"
        ]
      ]
    },
    "qualifying_deposit_originator": {
      "company_name": "BRISKPAY INC",
      "company_id": "18xxxxx922",
      "originating_bank": "A small bank in Delaware",
      "first_seen_on_our_platform": "2026-09-11",
      "accounts_credited": 16,
      "accounts_credited_that_opened_since_2026_09_01": 16,
      "credits": "One credit to each account, $200.00 to $240.00; no account has received a second credit",
      "moved_out_within_30_minutes": "15 of 16",
      "comparison": "A payroll originator's first month on our platform usually means a handful of accounts receiving recurring credits on a fixed weekday."
    },
    "referral_graph": {
      "referrer": {
        "id": "R1",
        "account": "x4836",
        "name": "Derrick Sandoval",
        "opened": "2026-07-21",
        "joined_through": "Referral link from an account we closed on 2026-09-02 for promotion abuse",
        "own_qualifying_deposits": "Two LONESTAR STAFFNG PAYROLL credits in August ($388.62, $412.05); none since",
        "devices": "An iPhone 12 from 2026-07-21 to 2026-08-30; since 2026-09-08 only dfp_7c21e09a4b (the emulator this account was opened on)",
        "referrals": "11 since 2026-09-08 (8 paid, the rest held); the annual cap is 10 paid referrals",
        "ledger": {
          "note": "Every posted item on the referrer's account since it opened on 2026-07-21; amounts signed",
          "columns": [
            "ts",
            "type",
            "amount_usd",
            "balance_usd",
            "description",
            "detail"
          ],
          "rows": [
            [
              "2026-07-22T00:40:02Z",
              "instant_transfer_in",
              60,
              60,
              "Instant transfer from card x5120",
              "debit card at a large national bank, name match DERRICK SANDOVAL"
            ],
            [
              "2026-07-22T20:39:46Z",
              "card_purchase",
              -40.32,
              19.68,
              "SHELL OIL 57444219 HOUSTON TX",
              "mcc 5542, chip"
            ],
            [
              "2026-07-26T03:14:19Z",
              "card_purchase",
              -11.95,
              7.73,
              "WHATABURGER #0687 HOUSTON TX",
              "mcc 5814, contactless"
            ],
            [
              "2026-08-07T08:01:09Z",
              "ach_credit",
              388.62,
              396.35,
              "LONESTAR STAFFNG PAYROLL",
              "SEC PPD; company_name LONESTAR STAFFNG; entry_description PAYROLL; individual_name DERRICK SANDOVAL"
            ],
            [
              "2026-08-08T21:53:01Z",
              "card_purchase",
              -41.42,
              354.93,
              "KROGER #0393 HOUSTON TX",
              "mcc 5411, chip"
            ],
            [
              "2026-08-12T04:34:38Z",
              "card_purchase",
              -10.01,
              344.92,
              "WHATABURGER #0687 HOUSTON TX",
              "mcc 5814, contactless"
            ],
            [
              "2026-08-12T09:00:00Z",
              "reward_credit",
              50,
              394.92,
              "Referral reward: you joined with a friend's link",
              "referee reward"
            ],
            [
              "2026-08-12T23:22:34Z",
              "card_purchase",
              -28.25,
              366.67,
              "DOORDASH*WINGSTOP",
              "mcc 5814, card on file"
            ],
            [
              "2026-08-14T19:44:03Z",
              "card_purchase",
              -11.21,
              355.46,
              "WHATABURGER #0687 HOUSTON TX",
              "mcc 5814, contactless"
            ],
            [
              "2026-08-16T01:37:06Z",
              "card_purchase",
              -11.51,
              343.95,
              "WHATABURGER #0687 HOUSTON TX",
              "mcc 5814, contactless"
            ],
            [
              "2026-08-21T08:01:09Z",
              "ach_credit",
              412.05,
              756,
              "LONESTAR STAFFNG PAYROLL",
              "SEC PPD; company_name LONESTAR STAFFNG; entry_description PAYROLL; individual_name DERRICK SANDOVAL"
            ],
            [
              "2026-08-24T16:49:17Z",
              "card_purchase",
              -33.99,
              722.01,
              "WAL-MART #0570 HOUSTON TX",
              "mcc 5310, chip"
            ],
            [
              "2026-08-28T00:56:31Z",
              "card_purchase",
              -11.56,
              710.45,
              "CHICK-FIL-A #02214 HOUSTON TX",
              "mcc 5814, contactless"
            ],
            [
              "2026-08-28T04:36:59Z",
              "card_purchase",
              -16.44,
              694.01,
              "WHATABURGER #0687 HOUSTON TX",
              "mcc 5814, contactless"
            ],
            [
              "2026-08-31T00:48:34Z",
              "card_purchase",
              -29.93,
              664.08,
              "SHELL OIL 57444219 HOUSTON TX",
              "mcc 5542, chip"
            ],
            [
              "2026-08-31T03:50:09Z",
              "instant_transfer_out",
              -654.12,
              9.96,
              "Instant transfer to card x5120",
              "push to debit card"
            ],
            [
              "2026-08-31T03:50:09Z",
              "fee",
              -9.96,
              0,
              "Instant transfer fee",
              "1.5%"
            ],
            [
              "2026-09-12T09:00:00Z",
              "reward_credit",
              50,
              50,
              "Referral reward: Alexis Lowe joined with your link",
              "referrer reward"
            ],
            [
              "2026-09-12T12:09:41Z",
              "instant_transfer_out",
              -49.25,
              0.75,
              "Instant transfer to card x8812",
              "push to debit card"
            ],
            [
              "2026-09-12T12:09:41Z",
              "fee",
              -0.75,
              0,
              "Instant transfer fee",
              "1.5%"
            ],
            [
              "2026-09-15T09:00:00Z",
              "reward_credit",
              50,
              50,
              "Referral reward: Malik Grant joined with your link",
              "referrer reward"
            ],
            [
              "2026-09-15T13:47:21Z",
              "instant_transfer_out",
              -49.25,
              0.75,
              "Instant transfer to card x8812",
              "push to debit card"
            ],
            [
              "2026-09-15T13:47:21Z",
              "fee",
              -0.75,
              0,
              "Instant transfer fee",
              "1.5%"
            ],
            [
              "2026-09-18T09:00:00Z",
              "reward_credit",
              50,
              50,
              "Referral reward: Brianna Foster joined with your link",
              "referrer reward"
            ],
            [
              "2026-09-18T14:43:34Z",
              "instant_transfer_out",
              -49.25,
              0.75,
              "Instant transfer to card x8812",
              "push to debit card"
            ],
            [
              "2026-09-18T14:43:34Z",
              "fee",
              -0.75,
              0,
              "Instant transfer fee",
              "1.5%"
            ],
            [
              "2026-09-19T09:00:00Z",
              "reward_credit",
              50,
              50,
              "Referral reward: Darius Mack joined with your link",
              "referrer reward"
            ],
            [
              "2026-09-19T12:50:08Z",
              "instant_transfer_out",
              -49.25,
              0.75,
              "Instant transfer to card x8812",
              "push to debit card"
            ],
            [
              "2026-09-19T12:50:08Z",
              "fee",
              -0.75,
              0,
              "Instant transfer fee",
              "1.5%"
            ],
            [
              "2026-09-22T09:00:00Z",
              "reward_credit",
              50,
              50,
              "Referral reward: Imani Vance joined with your link",
              "referrer reward"
            ],
            [
              "2026-09-22T12:47:15Z",
              "instant_transfer_out",
              -49.25,
              0.75,
              "Instant transfer to card x8812",
              "push to debit card"
            ],
            [
              "2026-09-22T12:47:15Z",
              "fee",
              -0.75,
              0,
              "Instant transfer fee",
              "1.5%"
            ],
            [
              "2026-09-24T09:00:00Z",
              "reward_credit",
              50,
              50,
              "Referral reward: Xavier Nash joined with your link",
              "referrer reward"
            ],
            [
              "2026-09-24T13:26:30Z",
              "instant_transfer_out",
              -49.25,
              0.75,
              "Instant transfer to card x8812",
              "push to debit card"
            ],
            [
              "2026-09-24T13:26:30Z",
              "fee",
              -0.75,
              0,
              "Instant transfer fee",
              "1.5%"
            ],
            [
              "2026-09-26T09:00:00Z",
              "reward_credit",
              50,
              50,
              "Referral reward: Cedric Ingram joined with your link",
              "referrer reward"
            ],
            [
              "2026-09-26T14:14:22Z",
              "instant_transfer_out",
              -49.25,
              0.75,
              "Instant transfer to card x8812",
              "push to debit card"
            ],
            [
              "2026-09-26T14:14:22Z",
              "fee",
              -0.75,
              0,
              "Instant transfer fee",
              "1.5%"
            ],
            [
              "2026-09-29T09:00:00Z",
              "reward_credit",
              50,
              50,
              "Referral reward: Roderick Pace joined with your link",
              "referrer reward"
            ],
            [
              "2026-09-29T12:06:03Z",
              "instant_transfer_out",
              -49.25,
              0.75,
              "Instant transfer to card x8812",
              "push to debit card"
            ],
            [
              "2026-09-29T12:06:03Z",
              "fee",
              -0.75,
              0,
              "Instant transfer fee",
              "1.5%"
            ]
          ]
        }
      },
      "second_referrer": {
        "id": "R2",
        "account": "x5302",
        "name": "Kiara Benton",
        "opened": "2026-08-30",
        "link_to_R1": "Logs in from device dfp_a93f10c2d7, which also opened 2 of R1's referees; pays out to card x3307, which 5 of the referees below also use",
        "referrals": "6 since 2026-09-11 (3 paid)"
      },
      "referees_of_R1_and_R2": {
        "columns": [
          "account",
          "name",
          "opened",
          "referred_by",
          "address",
          "device_id",
          "emulator",
          "qualifying_deposit",
          "payout_method",
          "status",
          "referral_reward"
        ],
        "rows": [
          [
            "x4776",
            "Alexis Lowe",
            "2026-09-08",
            "R1",
            "Apt 2A, Westglen Pointe Apartments, Houston TX 77063",
            "dfp_7c21e09a4b",
            "yes",
            "BRISKPAY INC $240.00 on 2026-09-11",
            "card x8812",
            "Open, balance $0.00",
            "Paid 2026-09-12"
          ],
          [
            "x3994",
            "Malik Grant",
            "2026-09-10",
            "R1",
            "Apt 3B, Westglen Pointe Apartments, Houston TX 77063",
            "dfp_7c21e09a4b",
            "yes",
            "BRISKPAY INC $215.00 on 2026-09-14",
            "card x3307",
            "Open, balance $0.00",
            "Paid 2026-09-15"
          ],
          [
            "x7375",
            "Isaiah Hardy",
            "2026-09-11",
            "R2",
            "Apt 7D, Westglen Pointe Apartments, Houston TX 77063",
            "dfp_a93f10c2d7",
            "yes",
            "BRISKPAY INC $240.00 on 2026-09-15",
            "card x8812",
            "Open, balance $0.00",
            "Paid 2026-09-16"
          ],
          [
            "x9627",
            "Brianna Foster",
            "2026-09-13",
            "R1",
            "PMB 2207, a mail-and-parcel store on Bellaire Blvd, Houston TX 77036",
            "dfp_a93f10c2d7",
            "yes",
            "BRISKPAY INC $225.50 on 2026-09-17",
            "card x8812",
            "Open, balance $0.00",
            "Paid 2026-09-18"
          ],
          [
            "x8574",
            "Darius Mack",
            "2026-09-14",
            "R1",
            "Apt 9A, Westglen Pointe Apartments, Houston TX 77063",
            "dfp_e5b8812f03",
            "yes",
            "BRISKPAY INC $210.00 on 2026-09-18",
            "card x3307",
            "Open, balance $0.00",
            "Paid 2026-09-19"
          ],
          [
            "x1284",
            "Destiny Kirby",
            "2026-09-16",
            "R2",
            "Apt 11C, Westglen Pointe Apartments, Houston TX 77063",
            "dfp_7c21e09a4b",
            "yes",
            "BRISKPAY INC $240.00 on 2026-09-21",
            "card x8812",
            "Open, balance $0.00",
            "Paid 2026-09-22"
          ],
          [
            "x7590",
            "Imani Vance",
            "2026-09-17",
            "R1",
            "Apartment, Houston TX 77099 (a different building)",
            "dfp_ee0ed3f1f0",
            "no",
            "BRISKPAY INC $212.40 on 2026-09-21",
            "card x8812",
            "Open, balance $0.00",
            "Paid 2026-09-22"
          ],
          [
            "x6511",
            "Xavier Nash",
            "2026-09-19",
            "R1",
            "PMB 1184, a mail-and-parcel store on Bellaire Blvd, Houston TX 77036",
            "dfp_a93f10c2d7",
            "yes",
            "BRISKPAY INC $212.40 on 2026-09-23",
            "card x3307",
            "Open, balance $0.00",
            "Paid 2026-09-24"
          ],
          [
            "x2013",
            "Nia Fowler",
            "2026-09-20",
            "R2",
            "Apt 12B, Westglen Pointe Apartments, Houston TX 77063",
            "dfp_a93f10c2d7",
            "yes",
            "BRISKPAY INC $200.00 on 2026-09-24",
            "card x8812",
            "Open, balance $0.00",
            "Paid 2026-09-25"
          ],
          [
            "x8188",
            "Cedric Ingram",
            "2026-09-22",
            "R1",
            "Apt 15A, Westglen Pointe Apartments, Houston TX 77063",
            "dfp_e5b8812f03",
            "yes",
            "BRISKPAY INC $200.00 on 2026-09-25",
            "card x8812",
            "Open, balance $0.00",
            "Paid 2026-09-26"
          ],
          [
            "x8431",
            "Roderick Pace",
            "2026-09-24",
            "R1",
            "Apt 16D, Westglen Pointe Apartments, Houston TX 77063",
            "dfp_7c21e09a4b",
            "yes",
            "BRISKPAY INC $212.40 on 2026-09-28",
            "card x3307",
            "Open, balance $0.00",
            "Paid 2026-09-29"
          ],
          [
            "x3244",
            "Kiara Toler",
            "2026-09-25",
            "R2",
            "PMB 0912, a mail-and-parcel store on Bellaire Blvd, Houston TX 77036",
            "dfp_7c21e09a4b",
            "yes",
            "BRISKPAY INC $231.00 on 2026-09-29",
            "card x8812",
            "Open, balance $0.00",
            "Held for review"
          ],
          [
            "x9263",
            "Jaylen Rhodes",
            "2026-09-27",
            "R1",
            "Apartment, Houston TX 77099 (a different building)",
            "dfp_88a209a8ae",
            "no",
            "BRISKPAY INC $212.40 on 2026-09-30",
            "card x6650 (prepaid; name check not supported)",
            "Open, balance $0.00",
            "Held for review"
          ],
          [
            "x2061",
            "Tavon Mills",
            "2026-09-29",
            "R1",
            "Apt 14C, Westglen Pointe Apartments, Houston TX 77063",
            "dfp_7c21e09a4b",
            "yes",
            "BRISKPAY INC $212.40 on 2026-10-06",
            "card x8812",
            "Under review",
            "Held 2026-10-06 (this review)"
          ],
          [
            "x6540",
            "Keisha Odom",
            "2026-10-01",
            "R2",
            "Apt 18C, Westglen Pointe Apartments, Houston TX 77063",
            "dfp_e5b8812f03",
            "yes",
            "BRISKPAY INC $210.00 on 2026-10-06",
            "card x8812",
            "Open, balance $0.00",
            "Held for review"
          ],
          [
            "x9024",
            "Tasha Quarles",
            "2026-10-03",
            "R1",
            "PMB 3350, a mail-and-parcel store on Bellaire Blvd, Houston TX 77036",
            "dfp_7c21e09a4b",
            "yes",
            "BRISKPAY INC $212.40 on 2026-10-06",
            "card x8812",
            "Open, balance $0.00",
            "Held for review"
          ],
          [
            "x9092",
            "Quentin Yates",
            "2026-10-04",
            "R2",
            "Apt 21B, Westglen Pointe Apartments, Houston TX 77063",
            "dfp_7c21e09a4b",
            "yes",
            "None",
            "card x3307",
            "Opened, no deposit yet",
            "Not triggered"
          ]
        ]
      }
    },
    "linked_accounts": {
      "note": "Accounts sharing an attribute with x2061, from our link analysis",
      "columns": [
        "link",
        "accounts"
      ],
      "rows": [
        [
          "Same device_id dfp_7c21e09a4b",
          "R1 x4836 and 7 referees of R1 and R2"
        ],
        [
          "Same payout card x8812",
          "R1 and 10 other referees of R1 and R2"
        ],
        [
          "Same building, Westglen Pointe Apartments",
          "10 other accounts, all opened since 2026-09-08, all referees of R1 or R2"
        ],
        [
          "Same sign-up IP 203.0.113.84",
          "6 other accounts opened in the last 30 days, 5 of them referees of R1 or R2"
        ],
        [
          "Same qualifying deposit originator BRISKPAY INC",
          "15 other accounts, all referees of R1 or R2"
        ],
        [
          "Same phone, email or SSN",
          "None"
        ]
      ]
    },
    "reward_history": {
      "this_account": "None before this reward",
      "referees_of_R1_and_R2": "11 referee rewards and 11 referrer rewards paid between 2026-09-12 and 2026-09-29 ($1,100), before the emulator, shared-device and shared-payout rules began holding rewards on 2026-09-29; none clawed back yet; every paid reward was pushed out to card x8812 or x3307 within 5 hours",
      "earlier_ring": "R1 itself joined through the link of an account closed on 2026-09-02 for promotion abuse, after 8 of its referrals were denied"
    },
    "customer_contact": "None",
    "rules_fired": [
      "REF-01 referrer has 5 or more referrals in 30 days (R1: 11)",
      "REF-04 qualifying deposit originator first seen on our platform under 30 days ago",
      "REF-06 over 90% of the qualifying deposit moved out within 1 hour",
      "DEV-02 emulator or app cloner detected at sign-up",
      "DEV-03 device seen on more than 2 accounts",
      "PAY-02 payout card used on more than 2 accounts",
      "ID-05 address doesn't match the verified identity's address history"
    ],
    "rewards_risk_score": 97,
    "reward_under_review": {
      "reward": "Referral reward: $50 to this account (referee) and $50 to R1 (referrer)",
      "promotion": "Give $50, Get $50",
      "triggered_by": "BRISKPAY INC ACH credit of $212.40 posted 2026-10-06T14:02:17Z, counted as a qualifying direct deposit (SEC PPD)",
      "held_at": "2026-10-06T14:05:00Z",
      "reviewed_at": "2026-10-07T15:12:00Z",
      "balance_now_usd": 0
    }
  },
  "questions": {
    "abuse_likelihood": {
      "type": "score",
      "instructions": "From the promotion owner's point of view, how likely is it that this reward is being claimed through abuse: by someone the terms exclude (an extra account of a person who already has one, a self-referral), or through qualifying activity that was faked, staged or paid for with money that will be reversed? A customer who simply meets the terms, even one who joined mainly for the reward, is not abuse.",
      "criteria": [
        "Very unlikely (under 10%)",
        "Unlikely (10-40%)",
        "Uncertain (40-60%)",
        "Likely (60-90%)",
        "Very likely (over 90%)"
      ]
    },
    "abuse_pattern": {
      "type": "choice",
      "instructions": "Which best describes how this reward was earned?",
      "criteria": {
        "legitimate": "No abuse: an eligible customer earned the reward through genuine qualifying activity",
        "multi_accounting": "Multi-accounting: a person who already has or had an account with us opened another, under their own or someone else's identity, to claim a one-per-person reward again",
        "referral_ring": "Referral ring: referral rewards collected through referred accounts that the referrer controls or recruited only to collect the reward, however their qualifying activity was produced",
        "fake_offer_completion": "Faked qualifying activity outside a referral scheme: sign-up, offer or cash-back rewards earned with completions from bots, emulators or install farms, or with deposits or purchases staged only to trigger the reward and then reversed or moved straight back",
        "bonus_bust_out": "Bust-out: rewards collected and the balance cashed out with money that is later returned or charged back, leaving us with a loss",
        "other_abuse": "Another kind of abuse of the promotion terms"
      }
    },
    "linked_to_other_accounts": {
      "type": "noul",
      "instructions": "Is the account under review controlled by the same person as one or more other accounts on our platform? Judge from shared devices, payment and payout methods, addresses, phone numbers, emails and identity details. A shared public or mobile-carrier network, or a family member with their own identity, phone and payment methods, does not make it the same person."
    },
    "action": {
      "type": "choice",
      "instructions": "What should we do with the reward under review?",
      "criteria": {
        "pay": "Pay the reward now",
        "hold_for_review": "Keep holding the reward and send the account to an analyst, who may ask the customer for more information or verification, before paying or denying",
        "deny": "Deny this reward under the promotion terms and keep the account open",
        "deny_and_close": "Deny the reward, claw back other rewards earned the same way, and close the account and the accounts it controls under the account agreement"
      }
    }
  }
}