Interagency CIP Guidance on Prepaid Cards — Who is the Customer?
April 4, 2016
The federal banking agencies have issued guidance on the applicability of customer identification program (CIP) requirements on accounts involving holders of prepaid cards. If the card is reloadable or if certain features are available such as overdraft protection, the bank may be required to treat the underlying cardholders rather than the third party account manager (such as an employer) as the “customer” for CIP purposes. Please see CBA’s Regulatory Compliance Bulletin prepared by Ted Kitada of Wells Fargo Bank and Chairman of CBA’s Legal Affairs Committee for more information.