FinCEN: Interagency Guidance to Issuing Banks on Applying Customer Identification Program Requirements to Holders of Prepaid Cards

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March 21, 2016

The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), and the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) (collectively, the Agencies), are publishing this guidance to issuing banks on the application of the joint regulations implementing the customer identification program (CIP) requirements set forth in Section 326 of the USA PATRIOT Act (referred to in this guidance as the “CIP rule”) to their prepaid cards.

Prepaid cards include those that are sold and distributed by third-party program managers, as well as cards that are used to provide employee wages, healthcare, and government benefits. The guidance clarifies that a bank should apply its CIP to the cardholders of certain prepaid cards issued by the bank.