We have a product that we sell: a stored-value, reloadable card branded by VISA and can be utilized at any merchant. Would this be considered exempt from the rules, as it is a "reloadable prepaid card" or would it be covered under the rules as it is a "network branded card redeemable at any merchant." It is marketed to the general public as a TravelMoney card and never as a gift card.
In addition, if it is not subject to the final rules, does it also exempt it from the requirements of a 5 year expiration and the prohibition of service fees?
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