Any idea how the USA PATRIOT Act will affect "stored value cards?" I'm wondering if we, as the issuing bank, will need to run each cardholder through ID verification, OFAC, etc.

If your stored value card program meets the "ongoing financial relationship" test, then I would say it meets the CIP definition of "account" and thus, CIP would apply.

Interesting question, and I agree with Jac. If this is similar to a money order, purchase and leave, I'd say no, there is no relationship. But if it is recharged from an account with you, by virtue of that account CIP applies.

We offer Visa Buxx stored value cards. My question was whether the teenager whose name the card is issued in is a "customer" under CIP. We require that the card be funded through an account at our bank so we know that the parent or guardian funding the account is already a customer.

We asked this question of the OCC and their response was that the teenager is not a customer and we do not need to perform verification and authentication as required under the CIP.

I would agree with that OCC opinion as the child is the receiver and not an accountholder. That would be consistent with other scenarios I have heard.