Topic: Refund Anticipation Loans (RALs)
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If we have customers who prepare tax returns and pay out tax refunds to their customers, would Regulation CC apply to the customers of the tax preparers, even though they do not have accounts with our organization?
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Regulation CC would only apply to the account holder, who is the tax preparer. In the situation you have described, where customers have signed an agreement stating that they cannot make withdrawals or deposits, the customers would not be considered account holders. The disclosure requirements and other rules in Regulation CC apply only to “customers”—a…