A joint release from several federal financial institutionregulatory agencies Monday clarified how the customeridentification program rule will pertain to prepaid cards issued by financial institutions.

Credit unions, banks and savings associations, among others,fall under the guidance that calls for a financial institution'sCIP to apply to prepaid cards provided by the institution. Underthe guidance, the institution's CIP would also apply to prepaidcards that are sold, distributed, promoted or marketed bythird-party programs on its behalf.

Additionally, financial institutions would be required to gatheridentifying information for the cardholder, including a minimum ofthe name, the date of birth, the address and an identificationnumber, such as the taxpayer identification number of thecardholder.

According to the guidance, the cardholder should also be treatedas the financial institution's customer under the CIP rule, even ifthe cardholder is not the named account holder and obtained thecard from an intermediary that uses a pooled account with theinstitution to fund institution-issued cards.

Further, third-party program managers should be treated asagents of the institution for purposes of the CIP rule, rather thanas the institution's customer. The institution is ultimatelyresponsible for compliance with the requirements of its CIP rule asperformed by that agent or other contracted third party, theguidance said.

The NCUA, Federal Deposit Insurance Corporation, Federal ReserveBoard, FinCEN and the Office of the Comptroller of the Currencycollectively issued the joint release.