Abstract
In the last few years, store gift certificates have matured into a diverse set of products including open loop prepaid cards capable of providing services traditionally reserved to banks. At the same time, tighter regulations on banks have raised the cost of bank accounts and driven many out of the banking market. Prepaid card providers including merchants like Walgreens are seeking to serve this new unbanked population with bank-like services including overdraft protection. Consumer groups have not given these new services a warm reception. In some cases, their concerns were warranted as prepaid programs made an end run around payday lending laws. However, recent actions have left companies in a quandary as to the precise limits of laws against deceptive and unfair practices. This paper seeks to survey regulatory actions, guidance, and current law to suggest a set of best practices that will allow companies to provide the innovative products that consumers are demanding while ensuring that they remain financially sound.
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