The American Banker has commentary on the new ruling that affects the funds in open-loop prepaid card accounts.
John L. Douglas, a partner in the Atlanta law firm Paul, Hastings, Janofsky & Walker LLP had this to say about the new ruling:
"It is one thing to say there is a deposit and there is insurance. That in and of itself is not all that big of a deal. The other issue that banks and program managers need to start worrying about really is: If you are going to create an insured-deposit relationship with a customer, what other regulatory requirements do you need to be worrying about as well? I don't know the answer."
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