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ARTICLE · 12 FEBRUARY 2018

Prepaid Cards: Deposit Accounts? Or Something Else? Answer: It Depends

Borden Ladner Gervais LLP
Borden Ladner Gervais LLP
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Borden Ladner Gervais LLP

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As new FinTech companies and traditional financial service providers look for new ways to provide financial services, the limits of our existing regulatory regimes have found themselves pressed.

CanadaFinance and Banking

As new FinTech companies and traditional financial service providers look for new ways to provide financial services, the limits of our existing regulatory regimes have found themselves pressed.  One development has been the use of prepaid cards and related personal financial management tools to provide services that look and function in many ways like a deposit account. 

Recently, B.C.'s Financial Institutions Commission ("FICOM") reviewed the structure of certain prepaid cards issued by All Trans Financial Services Credit Union Limited ("All Trans") and said that those cards were in effect a 'deposit account' and therefore All Trans was supposedly carrying on unauthorized deposit business in B.C.

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