"Cards, codes or other devices....for personal use...capable of being loaded with funds and redeemable upon presentation at multiple, unaffiliated merchants for goods or services....."

Now, I have to disclose that I haven't read even the whole preface yet, much less the reg itself. I'm trying to convince myself that the intention is to exclude our gift cards. They are VISA debit card products, but they are marketed as gift cards. But before I decide not to read the rest of this monster..... what about secured credit cards? They are reloadable pieces of plastic???? Anyone else giving these thought?

It's hard to reconcile "The Bureau believes it appropriate to cast a wide net" with trying to exclude cards due to how we market them or what they are called. (These secured credit cards are new to our bank, btw, so please send me to other reading if necessary.)

Secured credit cards aren't accounts or prepaid accounts under the current or proposed Reg E definition.

As for your Visa gift cards, which are covered by the Gift Card rule in 1005.20 because they are marketed as gift cards -- they would also be defined as prepaid account access devices under the proposed Prepaid Accounts Rule unless they are labeled as gift cards. To be excluded, a card would have to be BOTH marketed and labeled as a gift card.

Start reading ....

Ugh - makes you want to get a Marks A Lot pen and write the words "Gift Card" on the Visa Gift Cards that we offer. We don't even sell very many of them. I wish we would stop selling them.

What a way to spend my Christmas.....but reading regs isn't my least fav activity! And I came in and checked our gift cards first thing...they are labeled "gift card" right on the plastic. Feeling much better now. Still don't like our secured cards, but that's a topic for another area.

Now I just have to get in the hohoho spirit of sharing my reading with other members of the team that never read. I'll take that another area, too.

Hope you got that Sharpie for Christmas, ahou!

Thanks, as always, for sharing.