The information provided here represents the current structure and intended operation of IN TURN. We recommend reviewing this structure with your own legal and financial advisors before implementing.
IN TURN is a structured peer contribution system that facilitates rotating savings pools among employees. It operates as a voluntary employee benefit program, not a financial product.
IN TURN is NOT:
IN TURN IS: A program administrator that structures and facilitates voluntary peer-to-peer financial support among employees who choose to participate in a rotating savings pool.
The employer acts as a facilitator, not a financial intermediary. Your role is to:
The employer does NOT:
Key principle: Participation in InTurn is entirely voluntary. Employees opt in by signing a participation agreement. The employer facilitates but does not fund or manage the financial structure (unless the employer chooses to contribute voluntarily). InTurn acts as the program administrator, not a fiduciary.
InTurn operates as a structured peer contribution system, not a regulated financial product. However, we've designed the structure with the following considerations:
1. Not a Money Services Business: InTurn does not meet the definition of a Money Services Business under FinCEN regulations because it does not engage in money transmission for profit, does not issue stored value, and does not provide check cashing or currency exchange services.
2. Not a Lending Product: There is no borrowing, no interest, no repayment, and no credit underwriting. Participants contribute and receive payouts on a rotating basis—this is fundamentally different from lending.
3. Not ERISA-Covered: Because participation is voluntary, employee-funded, and not employer-sponsored as a retirement or welfare benefit plan, InTurn does not fall under ERISA regulations.
Disclaimer: Regulatory requirements and interpretations vary by jurisdiction. Consult your legal advisor to confirm that InTurn complies with applicable state and federal laws in your location.
Contributions: Employee contributions are made post-tax via payroll deduction. Employees have already paid income tax on the funds they contribute.
Payouts: Because contributions are made post-tax via payroll deduction, participants may not owe additional taxes on their lump-sum payout. Consult a tax professional for your specific situation, as tax treatment may vary.
Reporting: InTurn will provide annual statements showing total contributions and payouts for each participant once final tax treatment is determined.
Important: Employees should consult a tax professional to understand their specific tax situation. InTurn does not provide tax advice.
If you contribute or match funds: Employer contributions to the InTurn pool are generally deductible as a business expense, similar to other employee benefits. Consult your tax advisor for specific treatment.
If you only facilitate (no employer contribution): There are typically no tax implications for the employer. You're not funding the benefit, so there's no deduction and no reporting requirement.
Pooled employee contributions are held in a segregated bank account administered by InTurn. The employer does not hold, manage, or have fiduciary responsibility for these funds.
Account structure: Funds are held in a segregated bank account at a regulated financial institution. InTurn acts as the program administrator and maintains a ledger tracking contributions and payouts for each participant. Payouts are processed manually by InTurn based on admin-approved requests and the predetermined rotation schedule.
Relationship structure: Each employer signs a simple service agreement with InTurn. InTurn is the administrator, not a fiduciary. The employer facilitates employee access to the program and processes payroll deductions.
Transparency: Participants receive regular reports from InTurn showing the pool balance, total contributions, and rotation schedule. Individual payout requests remain confidential.
Transparency = Credibility: We disclose these risks upfront because informed participants make better decisions. IN TURN is designed to minimize risk through structure, transparency, and predictability.
InTurn collects and stores participant data (name, email, contribution amounts, payout history) to administer the program. We comply with applicable data protection laws and do not sell or share participant data with third parties except as required by law.
Employer access: The designated admin can approve payout requests and receive participation reports from InTurn, but individual participant financial details remain private unless the participant chooses to disclose them.
If disputes arise between participants (e.g., disagreements about rotation order, contribution amounts, or payout eligibility), InTurn provides mediation support. The employer is not responsible for resolving participant disputes.
Arbitration clause: Participants agree to binding arbitration for disputes related to InTurn participation. This is outlined in the participant terms of service.
The employer or InTurn may discontinue the program at any time. If the program is discontinued:
If you have legal or compliance questions about InTurn's structure, contact us at inturncollective@gmail.com. We're happy to coordinate with your legal counsel to address any concerns before you launch a pilot.
Consult your tax advisor for guidance specific to your organization. Tax treatment of pool contributions and payouts may vary based on your structure and jurisdiction. InTurn does not provide tax advice.