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Compliance Which new rules apply to branded gift cards
WASHINGTON (5/12/10)--Recent Federal Reserve amendments to Regulation E that restrict dormancy, inactivity and service fees and expiration dates that apply to store gift cards also cover card network-branded gift cards, according to the Credit Union National Association. In the May edition of CUNA’s compliance challenge, CUNA advises credit unions that the same rules that apply to gift certificates and general use prepaid cards that are used for personal, family or household purposes will also apply to branded cards, which are linked to companies such as Visa and Mastercard and are redeemable by retailers that accept the card brand. These cards are sold by many credit unions. The new rules governing gift cards will be implemented alongside a number of other provisions set forth by the Credit Card Accountability Responsibility and Disclosure Act of 2009. Under the CARD Act, gift cards that are sold on or after August 22 must "fully comply" with the new rules. However, CUNA adds, state laws that provide greater consumer protection regarding fees or expiration dates on gift cards will not be preempted by these new rules. Another Challenge Q&A explains that the Reg E overdraft rules do not require credit unions to send written confirmations to members when they elect to revoke their access to overdraft services for ATM and one-time debit card transactions. “The credit union only has to provide confirmation of the member's affirmative consent (opt-in) to the credit union’s overdraft service for ATM and one-time debit card transactions,” CUNA added. For this months compliance challenge, use the resource link.


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