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#2198290 - 11/15/18 04:29 PM Beneficial Ownership and Stored Value Cards
bsa18 Offline
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Joined: Jan 2018
Posts: 5
Is beneficial ownership required for legal entities that purchase stored value cards (such as a reloadable gift card)? I realize this boils down to whether stored value cards fall into the definition of an "account". I keep going back and forth. Looking for some assistance. Thank you.

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#2198310 - 11/15/18 05:36 PM Re: Beneficial Ownership and Stored Value Cards bsa18
fmissle Offline
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Joined: Jul 2007
Posts: 1,016
Pac NW
You're required to obtain BO information at the time an account is opened.

Account is defined in 1020.100(a) as
Quote:
(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.pdf

Generally, if the card is reloadable it looks like that would be a relationship and BO information would be required.

That's my interpretation.

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#2198492 - 11/16/18 05:54 PM Re: Beneficial Ownership and Stored Value Cards bsa18
bsa18 Offline
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Joined: Jan 2018
Posts: 5
Thank you, that was very helpful.

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