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Health Reimbursement Account › FinCEN

Bryan Cave Leighton Paisner

New Interagency Guidance Clarifies CIP Requirements for Prepaid Cards

Bryan Cave Leighton Paisner on

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

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