Regulatory Alerts2002-08-12
Pennsylvania Department of Banking Response on Money Transmission Activity for Prepaid Debit Cards
The Pennsylvania Department of Banking determined that a company acting as a co-brander for a national bank's prepaid debit card program must obtain a Money Transmitter Act license unless it maintains a formal agency relationship with the bank. The Department concluded that the submitted documentation was insufficient to prove such an agency relationship exists, thereby subjecting the company's activities to state licensing requirements. Additionally, the Department noted it lacked sufficient information to determine if affiliated third-party promotional partners require licensing and advised contacting the Office of the Comptroller of the Currency regarding the bank's permissibility.
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