When the Federal Reserve Board published its regulations for Debit Card Interchange Fees and Routing, the only thing that was crystal clear was the cloud of confusion seen from a distance. To help clarify its regulations, the FRB has published a FAQ.
The FAQ is primarily focused on areas the FRB recognized would be confusing or implausible to the industry. From the perspective of clarifying confusing aspects, the FAQ addresses how load options impact a product’s inclusion as a general use prepaid card. Relative to the implausible, the FAQ confirms that a prepaid card that implements a traditional bill pay solution is not eligible for the GPR exclusion. On the plus side, it also confirms that it is possible to use card information to pay a bill, which appears to validate that MasterCard’s prepaid bill pay product is a viable work around.