The U.S. Financial Crimes Enforcement Network (FinCEN) has prepaid cards on its mind. William Langford, FinCEN's associate director of regulatory policy and programs, said at the conference's opening panel that his agency plans to issue an advanced notice of proposed rulemaking asking for industry input regarding these products.

"We want to push this forward to update the MSB [money services business] regulation," said Langford.

Stored value products are currently included in the Bank Secrecy Act definition of money services business.

Langford also shared some numbers on suspicious activity reports (SARs) dealing with prepaids:

471 SARs filed referenced prepaid cards
137 were filed by banks
331 were filed by MSBs

Interestingly, the first SAR filed dealing with these cards was filed in May 1998.