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#697275 - 03/06/07 05:57 PM Gift Card / Stored Value
BSA4LIFE Offline
Gold Star
Joined: Nov 2003
Posts: 284
California
If a business sells gift cards that are redeemable only at their business,is this still considered stored value And does it matter if they are paper cards that are not 'electronically accessible'? And if they sell them for over $1000.00 per person per day make them a MSB?

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#697350 - 03/06/07 07:06 PM Re: Gift Card / Stored Value BSA4LIFE
GMetz Offline
Member
Joined: May 2006
Posts: 60
Kentucky
First, ANY card that gets money added to it is a Stored Value Card, whether it's for use in only one store, or a Visa type card that can be used anywhere. If the card is electronically acecssible, then it's a "Stored Value Card/Gift Card" and if it's paper it's still considered a gift certificate. I can't answer your last question with 100% certainty, but I'd say that a customer buying a gift card/stored value card or a gift certificate does NOT make them an MSB because it's the same as buying merchandise in the store. Anyone agree or disagree?

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#697367 - 03/06/07 07:26 PM Re: Gift Card / Stored Value GMetz
Anonymous
Unregistered

I think BSA4Life is asking if the merchant is an MSB. I'm not sure.

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#697402 - 03/06/07 07:57 PM Re: Gift Card / Stored Value
Compliancer Offline
Gold Star
Compliancer
Joined: Jan 2006
Posts: 334
San Francisco, CA
A paper card is not a stored value card.

And yes, this merchant is now an MSB if they exceed the $1000 threshold sales threshold using a stored value card product. The definition of an MSB is defined by the Dept of Treasury as including a seller of stored value cards above $1000 to any one person in any amount of transaction in the course of one business day.

Go here for a quick reference chart and another link directly to 31 CFR 103 with the official definition of money service business.

http://www.msb.gov/msb/index.html
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#697503 - 03/06/07 09:08 PM Re: Gift Card / Stored Value Compliancer
GLKS Offline
Gold Star
Joined: Nov 2006
Posts: 344

However not all issuers of stored value are required to register as an MSB.

From the FFIEC BSA/AML Examination Manual:

Stored value. — A person that is an MSB solely as an issuer, seller, or redeemer of stored value is not required to register. However, a person that is an MSB as an issuer, seller, or redeemer of stored value and engages in MSB activities (of a nature and value that cause the person to be an MSB on a basis other than stored value) must register.

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