I'm not sure I totally understand the Final Rule relating to Prepaid Access cards. Prepaid access card issuers are EXEMPT if they are 1)closed loop cards not to exceed $2000 value on any given day, 2)cards with funds provided by a govt agency and 3) funds for medical flex plans, HSA's, etc. However, if any of the above can be used 1)internationally, 2)transfer funds to another person or 3)reload at a non-depository institution, then they are subject to the regulation. So, anyone that qualifies for the regulation (unless they are acting soley as an agent) must register with FinCEN. Correct? Or is there more to this? Thanks!!

FinCEN is having a webinar about these prepaid cards on Nov 9.

If it is any consolation, I don't understand it either. Wish they would write this stuff in "bonehead" English.

Ha! I'm with you Donna since alot of the rules they come up with ARE for boneheads!!