We want to start issuing stored value cards. The cards can only be opened online. The money is placed in pooled funds at our bank.
- We are FDIC/TGAP institution, so would these cards be insured?
- Would CIP apply since they can reload the card? There is a sponsor of the cards and they can transfer money to the card holders. Do we need information on the card holders? We collect name, address, ssn, phone and e-mail for the sponsor and name, address, SSN, phone, date of birth and e-mail address for the card holder.
- Do they need to get a privacy notice?