Regulatory Alerts2008-03-10
Added
Ruling on Whether Certain Reloadable Card Operations Are Money Services Businesses
FinCEN determines that member-sponsored merchants and automated teller machines (ATMs) participating in the Prepaid Card Reload Program are not money services businesses. These entities are not classified as sellers of stored value because the member financial institution controls the transaction, verifies the customer, and bears the risk of loss. They are also not classified as money transmitters because their acceptance and transmission of funds is an integral part of the execution and settlement of the sale of stored value.
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