Comments on Prepaid Access Regulations

On behalf of the Retail Industry Leaders Association (RILA), we write with respect to the Financial Crimes Enforcement Network’s (FinCEN) final rules amending the Bank Secrecy Act (BSA) regulations regarding definitions and other regulations relating to prepaid access (Final Rules).1 We appreciated the opportunity to meet with you and other FinCEN policy staff today to discuss the retail industry’s concerns with the Final Rules and the need for an extension of the implementation date.