Regulatory Alerts2016-03-21
Interagency Guidance on Applying Customer Identification Program Requirements to Prepaid Card Holders
The Federal Reserve, FDIC, NCUA, OCC, and FinCEN issued guidance clarifying that issuing banks must apply Customer Identification Program (CIP) requirements to holders of certain prepaid cards. Banks are required to treat general purpose prepaid cards as accounts subject to CIP rules if they allow fund reloading or provide access to credit or overdraft features. The guidance specifies that for non-reloadable cards without credit features, the third-party program manager is the customer, whereas for reloadable or credit-enabled cards, the individual cardholder is the customer and must be verified.
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