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Emerging Regulatory Issues Facing Prepaid Payments: One Size Does Not Fit All

Published by: TowerGroup

Published: Dec. 27, 2004 - 14 Pages


Table of Contents


TowerGroup Take-Aways




Report Coverage




Background




The Emergence of Prepaid Products


Exhibit 1: Motivators for Prepaid Payment Products: Variations by Product

Exhibit 2: Revenue Models for Prepaid Payment Products

Exhibit 3: Expense Models for Prepaid Payment Products




Framing the Regulatory Discussion


Exhibit 4: US Federal and State Regulations Governing Prepaid Payment Products (2004)


1996-97: The Federal Regulators Take Up Product Regulation

2004: The FRB Regulation E Proposal

2004: The FDIC Rule Change

Banking Regulations That (May) Apply to Stored-Value Cards


Exhibit 5: Potential Impact of Various Regulations on Issuers Business Models for Prepaid Payment Products




The Other Regulatory Front: The States

State Consumer Protection, Unclaimed Property, and Money Transmitter Laws


Exhibit 6: A Sample of State Regulations Affecting Prepaid Payment Products Proposed or Enacted in 2004




Parsing the Proposals: A Framework for Action

Impact of Proposed Regulation on Issuers' Business Models




Summary

Abstract

Financial services institutions (FSIs) and other issuers of prepaid payment cards must seek to manage the definition of this market space. A two-pronged approach is key. First, FSIs must present an environment in which consumer convenience is paramount and the variety of these products is essential for maintaining that convenience. FSIs must also prepare to adapt to the regulatory changes that will impact their areas of issuance and seek to profitably manage their adaptation to these changes. This Research Note extends TowerGroup's coverage of prepaid payment products, focusing on key regulatory and legislative efforts at both the federal and state levels while predicting the likeliest impacts of these changes on this fast-changing market space.

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