Electronic Banking And Prepaid Card Developments

摘要

Electronic banking and prepaid card laws continue to develop, as this year's Survey of recent developments demonstrates. This Survey discusses final rules concerning the electronic delivery of consumer disclosures. This Survey also discusses an administrative ruling issued by the Financial Crimes Enforcement Network ("FinCEN") concerning the application of the Bank Secrecy Act ("BSA") to certain participants in a reloadable prepaid card program. Finally, this Survey discusses the Federal Deposit Insurance Corporation ("FDIC") General Counsel's Opinion No. 8 regarding the insurability of funds underlying certain prepaid cards.