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#1769081 - 12/19/12 10:14 PM CIP on Prepaid Cards
mll Offline
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Is a prepaid card considered an "account" under CIP rules?

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#1769167 - 12/20/12 02:36 PM Re: CIP on Prepaid Cards mll
Erl of Baltimore Offline
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Erl of Baltimore
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You need to look how the prepaid access program is structured as far as CIP and BSA are concerned. FINCEN published the final Prepaid Access Rule on July 26, 2011.
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#1769250 - 12/20/12 03:45 PM Re: CIP on Prepaid Cards mll
mll Offline
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Joined: May 2010
Posts: 131
Okay, thank you.

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#1769279 - 12/20/12 04:12 PM Re: CIP on Prepaid Cards mll
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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You also need to see how the cards are set up. When a bank is the issuer, the funds are often FDIC insured as separate deposits, sitting in subaccounts under a master account. Those are "accounts" and are subject to CIP. That is the most common situation I have seen in BSA audits.
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