After significant pressure from Congress and pursuant to a CARD Act mandate, on July 29, FinCEN published a rule amending the Bank Secrecy Act regulations to address “prepaid access.” As a result, non-bank “providers” and “sellers” of prepaid access may have to register with FinCEN as an MSB and may have to maintain a money laundering program, file suspicious activity reports, retain records, and collect customer identification information at the point of sale. A “prepaid program” is defined broadly to include most prepaid cards, but there are numerous exemptions, including exemptions for certain open-loop cards under $1,000 and certain closed-loop cards under $2,000. The rule becomes effective on September 27, 2011, but “providers” can register on January 29, 2012.