Summary outlines guidance
on CIP requirements for pre-paid cards

April 5, 2016 -- A summary of interagency guidance for applying customer identification program (CIP) requirements to holders of prepaid cards is now posted on the NASCUS website, outlining the guidance published by federal financial regulatory agencies – and FinCEN – late last month.

The guidance clarifies that a credit union should apply its CIP to certain prepaid cardholders by determining if CIP requirements apply to a particular prepaid card. In determining such, the summary notes, a credit union should determine whether the issuance of the prepaid card results in the creation of an account, and (if so) determine the identity of the credit union’s member.

The summary looks at four broad areas: determining the existence of an account; prepaid cards that should be treated as accounts; identifying the customer, and; expectations for contracts with third party program managers.

NASCUS summary of interagency guidance/CIP requirements to holders of prepaid cards