You're required to obtain BO information at the time an account is opened.
Account is defined in 1020.100(a) as
(a) Account. For purposes of §1020.220:
(1) Account means a formal banking relationship established to provide or engage in services, dealings, or other financial transactions including a deposit account, a transaction or asset account, a credit account, or other extension of credit. Account also includes a relationship established to provide a safety deposit box or other safekeeping services, or cash management, custodian, and trust services.
(2) Account does not include:
(i) A product or service where a formal banking relationship is not established with a person, such as check-cashing, wire transfer, or sale of a check or money order;
(ii) An account that the bank acquires through an acquisition, merger, purchase of assets, or assumption of liabilities; or
(iii) An account opened for the purpose of participating in an employee benefit plan established under the Employee Retirement Income Security Act of 1974.
Which doesn't directly answer the question. So I found FinCEN guidance that I think is still applicable and the answer would be,,, (maybe) it depends.
https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20160321a1.pdfGenerally, if the card is reloadable it looks like that would be a relationship and BO information would be required.
That's my interpretation.