Regulatory Alerts2012-06-08
Application of the Prepaid Access Rule to Bank-Controlled Programs
FinCEN issued this ruling to clarify that a bank cannot be designated as a 'provider of prepaid access' because banks are exempt from Money Services Business registration. The agency determined that if the bank exercises primary oversight and control over the prepaid program, no participant is required to register as the provider. Consequently, the requesting company is not an MSB provider, though it may still be classified as a seller of prepaid access depending on its sales practices and compliance with customer identification and transaction limit policies.
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