Buying and Selling Unused Gift Cards=MSB?

Posted By: ComplianceGurl, CRCM

Buying and Selling Unused Gift Cards=MSB? - 02/11/11 08:01 PM

Has anyone heard about these businesses that buy and sell unused gift cards? This is similar to an eBay store, they also buy and sell new/used merchandise. My question is, if a person purchased store valued cards over $1000 per day, would this make the business an MSB? Or am I looking into this way too much?? Any insight would be appreciated! Thanks in advance!
Posted By: Elwood P. Dowd

Re: Buying and Selling Unused Gift Cards=MSB? - 02/11/11 08:38 PM

I've heard of it, but I'm not comfortable with it.

The reg (MSB definition) talks about selling, issuing or redeeming stored value cards, not buying them. Your customer's business model did not exist at the time the reg was written. My opinion is that, as long as he stays below the $1,000 threshold, he's not an MSB. Keep in mind, even if he was an MSB, he would not be required to register if this is his only activity.
Posted By: ComplianceGurl, CRCM

Re: Buying and Selling Unused Gift Cards=MSB? - 02/11/11 08:44 PM

Thanks Ken!