Topic: Prepaid Cards
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Can a bank charge non-customers transaction fees when cashing an economic impact payment (EIP) Visa prepaid card or an EIP check?
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We do not believe that the Visa rules permit you to charge fees for manually cashing an EIP debit card, although you may be able to charge certain ATM fees if the card is cashed at an out-of-network ATM. As for cashing an EIP check, we believe that the same rules under the Uniform Commercial…
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What are “stored-value cards” under the Illinois Revised Uniform Unclaimed Property Act (Illinois RUUPA)? We used to issue Visa gift cards and are unsure whether they would be considered stored-value cards.
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We believe Visa gift cards would be considered “stored-value cards” under the Illinois RUUPA, since they are redeemable at multiple unaffiliated merchants — unlike “gift cards,” which are redeemable at a single merchant or affiliated merchants. Under the Illinois RUUPA, a “stored-value card” is a “card . . . issued on a prepaid basis primarily…
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For the error resolution notices required for our prepaid accounts, we generally provide an abbreviated notice on our periodic statements. However, for one of our prepaid card account products, we do not provide periodic statements but are providing the alternative electronic or written transaction histories. Can you review our error resolution notices and confirm that it is correct to use Model Form A-7(b) in that case?
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While we cannot review your institution’s error resolution notices for compliance with regulatory requirements, as we cannot provide legal advice, we can provide general guidance on the use of the model forms in Regulation E. We believe that your bank should use a modified version of the error resolution notice in Appendix A-3(b) when providing…
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If a cash deposit is made at a retail store to a prepaid card account, does the transaction description on the periodic statement need to include the name and location of the retail store? Does the answer change for a cash or a check deposit at an ATM? Also, for retail purchases that are made in person or online, should the periodic statement list the city and state? Is the street address required?
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Cash Deposits No, we do not believe your bank is required to list the name and location of a retail store on your periodic statement when a cash deposit is made to a prepaid account at the retail store. As to the retail store location, when a consumer initiates a transfer at an electronic terminal…
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Could you direct me to the Illinois Revised Uniform Unclaimed Property Act language that shortens the presumed abandonment period to three years for demand, savings, or time deposit accounts? Also, are there changes regarding gift cards or reloadable cards?
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Demand, Savings and Time Deposit Accounts The Illinois Revised Uniform Unclaimed Property Act (RUUPA), which becomes effective on January 1, 2018, changes the presumed abandonment period for many types of property, including demand, savings and time deposit accounts. The relevant section is copied and linked to in our resources below. Gift Cards The Illinois RUUPA…
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Can we charge cancellation and lost/stolen card fees on our general use, open loop, non-reloadable gift cards? If so, can we waive the fees? And, are we required to refund customers who cancel their gift cards?
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Lost/stolen card and cancellation fees We do not believe that Regulation E or Illinois law would prohibit a bank from charging fees for lost or stolen cards or for card cancellations, provided that such fees are disclosed in the card agreement. As a general rule, Regulation E restricts banks from charging three types of fees:…