I asked this question several months ago in the Need to Remain Anonymous thread but never got a response...
We have a division for prepaid cards, and are currently managing about a dozen different prepaid card programs. At the end of 2014, one of our prepaid programs closed down due the low volume of customers.
This was our first wind down of a prepaid program, and we researched all of the affected compliance areas; however, I had trouble determining exactly how long we should have kept the company's online banking site open. All of the cardholders accessed their statements online, and I couldn't find an exact timeframe to maintain the ability to access the online statements after the final close date.
We ended up allowing access for sixty days after the final date, but while I was researching the topic, I came across a document in BVS that stated 90 days was the required timeframe for allowing online statement access.
Does anyone know where that number came from? Or, does anyone know what the right answer is? I'm sure this isn't going to be our only wind down, and I'm still curious about the situation. Thank you!

You might want to consider the most recent CFPB prepaid card proposal and wait until that becomes final before making any policy decisions. There really are no specific requirements at this point.

Thank you! I've read the study but haven't found the time to read the 900 page proposal yet..

And thank you for not using agressive punctuation this time; I think you've responded to every single post I've created and I've never seen anyone use the question mark quite the way you do... Any particular reason you do this?????

I really do appreciate all of the assistance you've provided me. Thanks for taking the time to respond.