Prepaid Card Compliance Conference presented by the American Conference Institute
John Douglas, Partner in our Corporate Department and Chris Daniel, Of Counsel in our Corporate Department will be speaking at the Prepaid Card Compliance Conference presented by the American Conference Institute. The conference will take place on June 17-18, 2008 at The Madison, a Loews Hotel in Washington, DC.
Chris will be speaking during the morning session of June 17, 2008 at 10:15am. The title of his session is "State Regulatory & Enforcement Panel: Recent Developments and Challenges." The topics of discussion include:
How key state laws impact retailers, program managers, and issuing banks: -gift card, state unclaimed property and money transmitter statutes -comparison of state requirements -which prepaid products are covered expressly/implicitly by state regulations
Complying with state money transmission laws -who they apply to -who has to be licensed -products that are captured by requirements -who is exempt -how can you lose an exemption? -how to get licensed: what is required?
Building a national prepaid card program in light of different state laws
Open loop vs. closed loop: What are the regulatory differences?
Filling regulatory gaps: When can you apply traditional product requirements to prepaid products?
Latest enforcement actions in the prepaid context
Enforcement priorities and trends for 2008 and beyond
Prepaid products that are on regulators’ radar screens and why
John will be speaking during the afternoon session of June 17, 2008 at 1:45pm. The title of his session is "Reloadable Cards: Achieving Regulatory Compliance and Enhanced Customer Due Diligence." The topics include:
Managing the convergence of general purpose reloadable cards with checking accounts
Where and how loads/reloads can be done
When is it deposit taking? When is it a bank account?
When are state money transmitter licenses required?
Mitigating risk of lost/stolen cards
Who does OFAC screenings and how
Best practices for AML/Bank Secrecy Act compliance, including:-implementing enhanced customer due diligence for AML prevention-what type of information you need to gather from customers-verifying customer information
Unloading in a foreign country: How to monitor for AML and security purposes
Different prepaid products trigger different regulatory treatment. Have you applied the appropriate federal and state regulatory frameworks to each of your products? Have you overcome the legal and compliance challenges affecting conventional, new and emerging prepaid offerings, including gift cards, reloadable, payroll, health care and benefit cards? Many federal and state enforcers have become more aggressive – are you prepared?
The conference will offer legal and practical guidance for structuring products and mitigating risks associated with conventional, new and emerging prepaid card products. Topics will include:
Federal and state regulatory and enforcement frameworks: Expert updates and insights
Federal preemption in the prepaid context: When is it triggered?
AML updates and compliance strategies for prepaid products
Reloadable cards: Compliance, data security and AML best practices
Third party arrangements: Minimizing the risk of privacy and security breaches
Escheat and abandoned property laws: What happens to remaining value on gift cards?
Disclosure, fees and expiry dates: What are the limits?
Structuring partnerships with retailers
For more information or to register, please visit: