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#1872065 - 11/18/13 04:06 PM Reloadable debit cards
Anonymous
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If there is a monthly maintenace fee for a general purpose reloadable debit card, does that fee have to be on the card itself or will it be in compliance if the fee is listed in the Schedule of Services & Fees
Any information is greatly appreciated. Thank you

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#1872132 - 11/18/13 05:28 PM Re: Reloadable debit cards Anonymous
John Burnett Offline
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John Burnett
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Assuming that the card meets the definitions for a "general-use prepaid card" in Regulation E ยง 1005.20(a)(3) and isn't subject to any of the exceptions in that section, the fee you ask about would be covered by .20(d)(2), and therefore is required to be disclosed on the card.
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#1872185 - 11/18/13 07:13 PM Re: Reloadable debit cards Anonymous
Elwood P. Dowd Offline
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Elwood P. Dowd
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Next to Harvey
You may want to call it a prepaid access device rather than a debit card.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1872196 - 11/18/13 07:29 PM Re: Reloadable debit cards Anonymous
John Burnett Offline
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John Burnett
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Cape Cod
"prepaid access device" is an oxymoron.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#1872212 - 11/18/13 07:55 PM Re: Reloadable debit cards John Burnett
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
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Next to Harvey
Fortunately, the neologism came from FinCEN, not me.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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