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#1607440 - 09/22/11 07:44 PM Prepaid Access - limits?
PeeWee Offline
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I'm in the process of updating our MSB procedures. In light of the Final Rule on Prepaid Access, I want to go ahead and update the definitions section in our procedure. I've read the Final Rule (and re-read and re-read) and I haven't come to a conclusion on the limits.

For the definition of an MSB, we are all use to the "more than $1,000 per person per day" lingo (with the exception of money transmitters). Now, with "providers and sellers of prepaid access", does the $1,000 per person per day threshold apply? I've read so many exclusions (i.e. closed loop not to exceed $2,000....) that I'm left confused.

I need to uderstand the definition as we require MSBs to be approved by executive mgmt prior to opening an account. I would appreciate comments from anyone who has a clearer understanding than me. crazy

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#1613662 - 10/07/11 01:09 PM Re: Prepaid Access - limits? PeeWee
Jerseygirl Offline
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Jersey Shore
Like Pee Wee we are working on providers of prepaids. Has anyone heard how merchants will be implemening this? Will they develop bsa policies to not sell >1,000 to 1 person in 1 day? We have many customers - big and small retail that sell cards. Really stumped on this one. For our other MSB's we havestrick guidelines but they would be a burden to apply to all our sellers of prepaids.

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#1614444 - 10/11/11 06:44 PM Re: Prepaid Access - limits? Jerseygirl
leo_bsayer Offline
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Hello. I, too, have been wondering about the limits on prepaid access - is it really over $1,000.00 as other services are?

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#1614625 - 10/12/11 12:39 PM Re: Prepaid Access - limits? leo_bsayer
BSA all the way Offline
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I too would love to hear from others! thanks :o)
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#1614626 - 10/12/11 12:46 PM Re: Prepaid Access - limits? PeeWee
Elwood P. Dowd Offline
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The $1,000 per person, per day is uniformly applied to all types of MSBs other than money transmitters. Given you pre approval policy, I suggest you just identify them and then point any possible exemption to the reviewing body.

FinCEN did a webinar on the changes to the MSB definitions, but they specifically excluded "prepaid" saying they would do a separate program on that topic. In addition, FinCEN has granted regulatory relief in connection with prepaid providers. In effect, you may identify them through due diligence, but verification of their compliance in the near term is conjectural.
Last edited by Ken_Pegasus; 10/12/11 01:24 PM.
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#1614641 - 10/12/11 01:27 PM Re: Prepaid Access - limits? Elwood P. Dowd
ACBbank Offline
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This is taken from the Prepaid Access Guidance issued in July:

"... all closed loop prepaid access that is issued in amounts of $2,000 or less will be excluded from the definition of prepaid program."

In my opinion, closed loop prepaid access in amounts below $2,000 is exempt from the defintion of a prepaid program.
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#1615074 - 10/13/11 10:33 AM Re: Prepaid Access - limits? ACBbank
Elwood P. Dowd Offline
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I wasn't suggesting otherwise, just that the bank move the information about exemption to the committee and not let the frontline employee make the decision aobut opening the account.
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#1615123 - 10/13/11 01:11 PM Re: Prepaid Access - limits? Elwood P. Dowd
ACBbank Offline
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I misunderstood your post Ken. Point taken.
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