On February 20, 2025, the Office of the Comptroller of the Currency (“OCC”) announced that they had entered into a formal agreement with Patriot Bank, National Association (“Patriot Bank”), following a comprehensive...more
22nd National Forum on Prepaid Accounts Compliance is going Virtual! The conference will take place on February 22—24, 2022 (EST) via an interactive online platform. Formerly ACI’s Prepaid Card Compliance Forum, the evolved...more
Below is a summary of some of the significant legal and regulatory actions that occurred over the past week. This alert is not intended to be a comprehensive list of all such developments, but rather a selection of...more
Banks and credit unions that issue reloadable, general purpose prepaid cards must apply Customer Identification Program (CIP) procedures to those cardholders, according to guidance issued by the federal banking regulators and...more
On March 24 FinCEN issued a second set of the Frequently Asked Questions meant to clarify key questions that have persisted regarding compliance with the Prepaid Access Rule. The FAQs covered five questions....more
Regulatory Developments - SEC Issues FAST Act IM Guidance - The SEC published an IM Guidance Update highlighting two exemptions from registration under the Investment Advisers Act of 1940 (the Advisers Act) that...more
On March 21, 2016, the Banking Agencies, along with the Financial Crimes Enforcement Network (FinCEN), issued guidance to banking institutions on applying customer identification program (CIP) requirements when issuing...more
On March 24, 2016, the Financial Crimes Enforcement Network issued a set of frequently asked questions (FAQs) regarding prepaid access. This set of FAQs is meant to supplement a previous set of FAQs issued in 2011 by FinCEN...more
On March 21, 2016, FinCEN and the federal bank regulatory agencies published Guidance to issuing banks on the CIP requirements applicable to prepaid cards. While the Guidance referred to “prepaid cards,” footnote 5 to the...more