FinCEN issued a final rule amending Bank Secrecy Act provisions
regarding money services businesses. The rule renames "stored
value" as "prepaid access" without changing the
meaning of the term. The obligations of parties that distribute
"prepaid access" have been expanded by replacing the
terms "issuer" and "redeemer" of stored value
with a new, broader category of participant termed "providers
of prepaid access." The rule puts in place suspicious activity
reporting and customer and transaction information recordkeeping
requirements on both "providers" and "sellers"
of prepaid access. The rule exempts from its coverage (1) prepaid
access products of $1,000 or less and payroll products if they
cannot be used internationally, do not permit transfers among
users, and cannot be reloaded from a non-depository source; (2)
closed-loop prepaid access products sold in amounts of $2,000 or
less; and (3) government funded and pre-tax flexible spending for
health and dependent
