News & Analysis as of

Customer Identification Program (CIP) Prepaid Payment Products

Manatt, Phelps & Phillips, LLP

Prepaids in Focus: Federal Regulators Clarify CIP Rules

The federal banking agencies and the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) have issued guidance to banks to clarify how the Bank Secrecy Act's customer identification program (CIP)...more

WilmerHale

Federal Regulators Clarify Bank CIP Obligations for Prepaid Cardholders

WilmerHale on

Banks and credit unions that issue reloadable, general purpose prepaid cards must apply Customer Identification Program (CIP) procedures to those cardholders, according to guidance issued by the federal banking regulators and...more

Eversheds Sutherland (US) LLP

Interagency Guidance: CIP Requirements Apply to Certain Prepaid Cards

On March 21, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency (OCC), and the U.S. Department of...more

Locke Lord LLP

Banking Agencies, FinCEN Issue Guidance on Applying CIP Requirements to Prepaid Cards

Locke Lord LLP on

On March 21, 2016, the Banking Agencies, along with the Financial Crimes Enforcement Network (FinCEN), issued guidance to banking institutions on applying customer identification program (CIP) requirements when issuing...more

Bryan Cave Leighton Paisner

New Interagency Guidance Clarifies CIP Requirements for Prepaid Cards

On March 21, 2016, FinCEN and the federal bank regulatory agencies published Guidance to issuing banks on the CIP requirements applicable to prepaid cards. While the Guidance referred to “prepaid cards,” footnote 5 to the...more

Morrison & Foerster LLP

New Agency Guidance on Applying CIP Requirements to Prepaid Cardholders

In response to continuing concerns about the vulnerability of prepaid cards to criminal and terrorist abuse, five regulators issued interagency joint guidance today clarifying bank obligations to identify prepaid card...more

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