The Nonprofit s Guide to Prepaid Cards

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1 Brought to you by the Center for Financial Services Innovation With support from the Network Branded Prepaid Card Association, NetSpend Corporation, and the Annie E. Casey Foundation

2 Dear Reader: Prepaid cards are everywhere. Look around, and you ll see them offered online; on television; in supermarket or retailer checkout lines; by check cashers and tax preparers; and even in some bank lobbies. In 2009, the FDIC estimated that approximately 10 percent of U.S. households, including 12 percent of unbanked and 16 percent of underbanked households, use prepaid cards, and that number is increasing rapidly. The Center for Financial Services Innovation (CFSI) works to transform the financial services marketplace so that underbanked consumers can achieve financial prosperity. Since our inception in 2004, we have championed prepaid cards as a financial product that, with the right features, pricing, and consumer protections, can provide real benefits to the country s million unbanked and underbanked households. CFSI created this resource guide for nonprofit organizations that are working on consumer finance issues and are interested in learning more about prepaid cards. The guide provides a basic primer on prepaid, as well as tools to help you explore how to incorporate prepaid into your programming. It draws from CFSI s wealth of research and experience with underbanked consumers, the prepaid industry, and nonprofit organizations efforts to connect the two. Who Should Read This Guide? Nonprofit community-based organizations Nonprofit policy, research, and/or advocacy organizations Regulators/government officials Funders After reading this guide, we hope you will, at a minimum, have a better understanding of prepaid cards and their potential benefits. We also hope you will be better equipped to incorporate prepaid into your programming to the extent that it fits with your mission and capacity whether that means being ready to answer your clients questions or going so far as partnering with a financial services company to distribute the cards yourself. What This Guide Does Not Include This guide does not include a ready-made curriculum for educating consumers about prepaid or a train-the-trainer program. It also does not provide legal or business advice, nor does it offer an organized list of prepaid card providers or details about particular card programs fees and features. 1 Given the industry s size and its rapidly evolving nature, this information is difficult to gather and to keep current. Most importantly, this guide is not intended to make decisions for your organization, but rather it will reveal what additional information you need to gather so that you can make your own decisions about how to engage with prepaid cards. Stay in Touch We wish you the best of luck as you begin your work with prepaid cards. As you go forward, we want to hear from you. We welcome your feedback on this guide and encourage you to us at with your questions and comments, and to tell us about your experiences, innovations, and best practices. The CFSI Team September There are many online prepaid card comparison tools such as CreditCards.com Credit Card Guide, and Compare Cards however CFSI cannot vouch for the accuracy or completeness of the information provided on these websites. 2

3 Acknowledgements This guide would not have been possible without the generous support of our sponsors the Network Branded Prepaid Card Association (NBPCA), NetSpend Corporation, and The Annie E. Casey Foundation. CFSI would also like to acknowledge Joshua Wright, who contributed significantly to this project, as well as Jennifer Sierecki, Janet Raffel, and Katherine Lucas-Smith, who reviewed drafts and provided useful feedback. 3

4 Table of Contents Introduction....5 A Role for Nonprofit Organizations About This Guide Part I: Prepaid Primer....7 What Is a Prepaid Card? How Do Prepaid Cards Work? Short-Term Loans/Line of Credit Fee Structures How Do Prepaid Cards Compare with Other Payment Products? Comparison with Other Transactional Products A Note About Wage Garnishments Overdraft Protection on Prepaid Cards The Prepaid Industry Industry Structure Economic Overview of the Industry Legal and Regulatory Issues Benefits and Issues for Consumers Potential Cost Savings with Prepaid Part II: Opportunities for Nonprofits to Engage with Prepaid The Engagement Continuum Key Considerations in Choosing an Engagement Strategy Levels of Engagement with Prepaid Cards Information and Education Referral and Partnership Distribution Conclusion Appendix A: Case Studies Understanding Clients Financial Services Needs One Nonprofit s Distribution Experience Appendix B: Legal and Regulatory Issues that Impact Nonprofit Prepaid Card Distribution Appendix C: Selecting a Prepaid Card Provider Partner About CFSI About the Sponsors

5 Introduction An estimated million American households are considered unbanked or underbanked. 1 This means they either have no account relationship with a mainstream bank or credit union, or if they do, they also rely on nontraditional financial services such as check cashing, money orders, and payday loans to meet their financial services needs. These underbanked consumers spend $13 billion each year on non-bank basic financial service transactions. 2 Many of these transactions are costly, but individuals rely heavily on these non-bank providers because traditional financial services often do not meet their needs. The underbanked need the ability to turn their paychecks and/or government benefits checks into cash quickly, pay bills, buy basic necessities, establish savings, transfer money to friends and family, borrow money for emergencies, and build assets over the longer term. A number of financial institutions and other organizations are developing solutions to address the needs of this underbanked market. Many banks and credit unions offer low-cost or free checking and savings accounts, and some offer payday loan alternatives and check-cashing services. However, low-cost, high-quality financial products and services are not widely available in all communities across the country, and those that are do not necessarily meet all of the needs of the large and multifaceted underbanked population. General-purpose reloadable prepaid cards present a promising part of the solution to meeting the financial needs of the underbanked. These cards function like electronic bank accounts without checks. Consumers can load funds onto their cards and can spend only what they load, providing immediate liquidity while limiting the risk of overdraft. Prepaid cards may be a good entry-level financial product for individuals without a traditional checking account. Like a bank account, they provide a safe way to carry an account balance, manage cash and because they can generally be used wherever MasterCard and Visa are accepted pay for purchases. Some have attached savings accounts with automated deposits features that can help people build savings. Furthermore, prepaid cards may encourage the use of additional financial services, moving individuals into the economic mainstream and onto a path toward greater financial prosperity. Research suggests that many consumers derive benefits from their prepaid cards: in a 2009 survey of 400 underbanked prepaid card users, conducted by CFSI and the Network Branded Prepaid Card Association, 78 percent of respondents told CFSI that their cards were very or extremely useful, 74 percent said they were very likely or certain to recommend the card to others, 60 percent used their cards weekly, and 12 percent reported daily use. 3 However, prepaid cards may not be for everyone. A card s usefulness depends on its associated fees and features, as well as the needs and behaviors of customers using the card. A useful product is generally thought to enable customers to meet their transactional needs in a cost-effective way and to provide them with a path to savings and credit-building opportunities. 1 The Federal Deposit Insurance Corporation s (FDIC s) December 2009 National Survey of Unbanked and Underbanked Households [ estimates 9 million unbanked households and 21 million underbanked, while CFSI s 2008 Underbanked Consumer Study [ estimates 18.5 million unbanked households and 21.6 million underbanked. Differences in the unbanked estimates are likely due to differences in research methodologies. 2 CFSI estimate based on publicly available financial services transaction volume data and average industry fees. 3 Satisfaction with and Usage of Prepaid Cards, NBPCA/CFSI Survey Results, April

6 INTRODUCTION A Role for Nonprofit Organizations General purpose reloadable prepaid cards are widely available, but not well understood. As prepaid cards are a potentially beneficial product in helping consumers meet their short-term financial transaction needs and possibly their longer-term savings and credit-building goals, nonprofit organizations can play a critical role in shaping the public discourse and educating consumers about the products, helping them make informed choices. In addition, some organizations may decide to go further and more directly connect consumers to prepaid card products by making referrals to individual or multiple providers or becoming distributors of cards themselves. Nonprofits can add significant value in the prepaid supply chain, as the prepaid card industry is increasingly coming to recognize. Over the past few years, CFSI has seen growing interest among nonprofits in prepaid, and received increased requests for information about the product and opportunities to engage more deeply with the industry. We conducted two unpublished surveys of nonprofit organizations: one in late 2008 with 125 respondents that collectively serve more than 5 million underbanked consumers; and the second in late 2009 with 51 respondents, all engaged in free tax preparation. In both surveys, 78% of respondents said they would consider incorporating information about prepaid cards into their financial education programming, and the majority also expressed an interest in distributing cards to their constituents, with 14% already doing so. About This Guide This guide is designed to be a practical tool for nonprofits at various levels of understanding and interest in prepaid cards. The guide has two main parts: 1. Prepaid Primer this guide will provide a detailed overview of prepaid cards, how they work, the industry structure, and the benefits and issues for consumers. 2. Opportunities for Nonprofit Organizations this guide will outline several options for nonprofits to engage with prepaid, strategic considerations to help you select the right approach, and tips for success with the path chosen. After reading this guide, we hope you will have an improved understanding of prepaid cards and will be better equipped to incorporate prepaid into your organization s programming. 6

7 Part I: Prepaid Primer What Is a Prepaid Card? The term prepaid card refers to a wide range of cards that store money electronically and serve a variety of purposes. Prepaid phone cards were first introduced in the 1970s. Since then, the product type has expanded to include a wide range of related products, including store gift cards, healthcare flexible spending and defined benefit cards, federal and state benefits cards, payroll cards, and general-purpose cards. Cards can be grouped based on two criteria: they can be (i) either closed-loop or open-loop and (ii) either one-time use or reloadable. Closed-loop The money stored on these cards can be used only in certain stores and/or on certain goods and services. Open-loop These cards are issued by a financial institution and the funds may be accessed in any location that accepts the card payment network (e.g., MasterCard, Visa ) for any type of purchase. One-time use These cards can be loaded only once. When the money is spent, the card is no longer useable. Reloadable These cards can be reloaded with money again and again. Furthermore, the main application of the card is often determined by who loads funds onto the card. As illustrated in Figure 1 on the next page, these parameters map out the prepaid card space. 7

8 PART I: PREPAID PRIMER Travel General Purpose Reloadable* Open-loop Incentive/Bonus Disaster Relief Rebate Refund Payroll Social Security Who Loads the Card? Employer Corporate Government Consumer Welfare * General Purpose Reloadable Cards are the focus of this guide Closed-loop Gift Promotional Phone Cards Money Transfer Healthcare and Defined Benefit One-time use Reloadable Figure 1 Types of Prepaid Cards This guide focuses exclusively on general-purpose, open-loop, reloadable (GPR) prepaid cards carrying one of the major payment network brands (such as MasterCard and Visa ). GPR cards have many advantages over closed-loop cards, including wider acceptance and more consumer protections; closed-loop cards facilitate spending only within the closed loop. For the rest of the guide, prepaid cards will refer only to general-purpose, open-loop, reloadable (GPR) prepaid cards. 8

9 PART I: PREPAID PRIMER How Do Prepaid Cards Work? Prepaid cards function like checkless checking accounts. They enable the user to load money onto the card, store the money safely, and spend or withdraw the funds in a variety of ways. Technically, prepaid cards are debit cards, meaning they are plastic cards issued by a financial institution that are used to make purchases. That purchase amount is deducted directly from the cardholder s account. However, the term debit card is most commonly used to refer to cards associated with checking accounts, and that is the definition used in this guide. Prepaid cards are a type of debit card with no associated checking account. Prepaid cards are issued by financial institutions, carry one of the major payment network brands, and are accepted wherever those network brands are accepted, just like a debit card associated with a checking account. The features and fees associated with the cards vary widely. Tables 1A and 1B (pages 10 and 11) summarize basic and advanced card features. Information about pricing and fees can be found in Table 2 (page 13). The vast majority of prepaid cards include all of the basic features, which enable a user to handle most simple financial transactions, and a growing number include the types of advanced features described below. Figure 2 provides a visual representation of how prepaid cards work. 1 Load/reload money onto FDIC-insured card 2 Store and manage money 3 Spend money in a variety of ways Direct Deposit General Spending Savings ATM Withdrawal Loading Networks (e.g., Green Dot, MoneyGram, Western Union) Government Benefits Tax Refunds Proprietary Loading Networks Reloadable Prepaid Card Photo Network Logo Cardholder Name 12/10 Check balances via: Online Text Message Alert Phone Online Budgeting ATM Retail Point of Sale PIN Signature Retail Cash Back Electronic Bill Pay Remittance Transfer to a 2 nd Card Key Basic Features Advanced Features Figure 2 How Prepaid Cards Work 9

10 PART I: PREPAID PRIMER Table 1A Basic Card Features Feature Cash loading Direct deposit Point of sale (POS) purchase with your signature POS purchase with a Personal Identification Number (PIN) ATM cash withdrawal Cash back with purchase Check balance online Check balance over the phone Check balance at an ATM FDIC pass-through insurance Fraud protection Explanation Prepaid card users can add funds onto their prepaid cards in-person at MoneyGram and Western Union locations, as well as at many check cashers, grocery stores, and convenience stores that participate in the GreenDot, ReadyLink, or repower prepaid networks (see Figure 3 on page 18). Paychecks (if employer offers direct deposit) or government benefits can be directly deposited onto the card, usually for free. Pay for purchase in stores anywhere the network brand is accepted, and sign as you would with a credit card purchase. Pay for purchase in stores anywhere the network brand is accepted, and type in your confidential PIN as you would with a debit card. Withdraw money at any ATM in the card s network (e.g. Cirrus, Plus, etc.). If you use an ATM that is not owned by the issuing bank, there are often associated fees from both the card company and the bank or company that owns the ATM. Several card programs allow access to surcharge-free ATM networks, like Allpoint. Withdraw money from the account for free at most major supermarkets and drugstores when you make a purchase. Use a secure password to check your card balance online, usually for free. Call a phone number to check your card balance using an automated system or with a live customer service agent. If you request to speak to an agent, there is often a fee. Use an ATM in your card s network to check your card balance, usually for a fee. FDIC insurance is a basic consumer protection most commonly associated with checking and savings accounts. It insures customer deposits at FDIC member banks for up to $250,000 in the event of a bank failure. Since 2008, FDIC insurance has been available for individual prepaid card account holders as long as certain conditions are met by the prepaid provider. Mainly, the pooled account at the issuing bank must be identified as a custodial account, and the funds deposited by the provider at an FDIC-insured depository institution must be identifiable and traceable to the individual card account holders. Most major card providers comply with these requirements, but this should be confirmed before entering into an agreement with any prepaid card provider. FDIC insurance is a particularly important benefit for prepaid card users, who tend to have lower incomes and can least afford to lose access to their money. Payroll card accounts are covered by the Electronic Fund Transfer Act (EFTA) and offer a full range of errorresolution procedures. Most issuers of GPR cards provide EFTA-like protections for cardholders. Further, GPR cards are subject to the card brands zero-liability policies. Like a credit card, if the card is used fraudulently, the cardholder can dispute the charge and cannot be held liable for more than $50 in charges. Unlike a credit card, this is not a legal requirement, but it is the current practice for MasterCard and Visa. 10

11 PART I: PREPAID PRIMER Table 1B Advanced Card Features Feature Online bill pay Credit building Savings account Online budgeting Account information via text messaging Second card Remittance Photo Line of credit/ Short-term loan Overdraft protection Proprietary loading network Person-to-person transfers Insurance Below are the most common advanced features on prepaid cards. However, the industry is evolving rapidly, and new features are being introduced regularly. For any nonprofit organization actively engaged with prepaid, it is important to stay abreast of new developments and changes. 4 Explanation Allows the cardholder to pay bills securely online. Payment can be made electronically, or a paper check can be sent if the payee does not accept electronic payment. This is very similar to the bill pay feature offered on many checking and savings accounts. Cardholders who pay recurring bills through online bill pay can elect to have regular monthly payments reported to an alternative credit bureau such as Payment Reporting Builds Credit (PRBC) 4, enabling consumers to build a credit record. Provides a way to set aside money into a separate savings account linked to the card, either a separate card for the savings account or a savings wallet connected to the same card. This money cannot be spent unless it is intentionally moved from the savings account into the general spend portion of the card. Some cards allow cardholders to set up recurring automatic transfers from the general spend account into the savings account. Preliminary data show that having an automated savings account is one of the best tools to help people build savings. Many prepaid card providers offer a competitive Annual Percentage Yield (APY) on savings. Enables cardholders to set monthly budget targets by category and in total. Cardholders receive automatic alerts via or text message when they have gone over budget. Cardholders can sign up for both text message alerts that are automatically sent to them (i.e., cardholders can receive a text every time they perform a transaction with the transaction amount and current remaining balance, or daily text messages with current balance) and/or for the capability to send text messages to request specific information (e.g., by sending a one-word text message reading balance to a short code, the cardholder instantly receives a text back with their current available balance). There are two types of second cards. One allows access to all the funds on the card, like a joint card. The other only allows access to amounts specifically transferred onto the second card. Enables transfer of money to other countries, either for pick up or for withdrawal off of a second card. A picture of the cardholder on the card makes the card a secondary form of identification and provides added security. The cardholder can apply for a short term loan on the card. This is usually available only if you have recurring direct deposits. The loan is automatically paid back when the next direct deposit occurs. (See sidebar on Short Term Loans/Lines of Credit on page 12.) Many prepaid card providers offer an opt-in overdraft protection feature tied to a card for a fee that enables cardholders to make purchases or ATM withdrawals for amounts greater than the balance in their card account. (See sidebar on Overdraft Protection on page 16.) Allows nonprofit organizations that distribute cards to offer reloading services on-site. Some prepaid companies allow free or low-cost transfers of funds between their cardholders via the Internet or text message. Some prepaid cards offer insurance benefits such as Accidental Death and Dismemberment coverage at no or low cost. 4 For more information about PRBC, see 11

12 PART I: PREPAID PRIMER Short-Term Loans/Line of Credit Short-term loans or lines of credit are increasingly offered through prepaid cards, and such products are evolving rapidly. Fees and interest rates for these credit products vary widely. While most are lower cost than payday loans, many still may be considered high-priced. Nonprofits can help clients determine whether such products are right for them. Used occasionally and paid off promptly and in full, such products can be beneficial to the consumer who has few or no other borrowing options. When used frequently or to roll-over to pay off other loans, they can impose an untenable debt burden on the customer. Below are two examples of credit products tied to prepaid cards with different pricing, terms, and features. Examining these products will help you better understand the short-term loan/line of credit services offered in the prepaid card industry. iadvance ( Offered by Metabank, iadvance is available to consumers that have direct deposit onto an eligible prepaid card. The consumer applies and receives the credit limit online or by phone, and the loan is made and becomes available in a matter of minutes. The fee is $2.50 for every $20 advanced, resulting in an APR of 150 percent. The entire loan amount is deducted off of the card at the next direct deposit. Emerald Advance ( Offered by H&R Block Bank, this service functions as a year-round unsecured line of credit at 36 percent APR and a $45 annual fee. Individuals can repeatedly borrow and repay throughout the year, but the line of credit (up to $1,000) must be paid down each year by February 15. The line of credit is established when a customer establishes direct deposit to an associated prepaid card (H&R Block Emerald Prepaid MasterCard ) or makes a deposit of $300 $1,000 in an associated savings account (H&R Block Emerald Savings account), thereby reducing the APR to 9 percent. The borrower must make a monthly minimum payment amount of $40 or 4 percent of the outstanding balance, whichever is greater, and can pay down their line of credit with a portion of their tax refund. 12

13 PART I: PREPAID PRIMER Table 2 Common Prepaid Card Fees Fee Structures Two pricing models prevail in the industry today. One charges a moderate monthly fee (e.g., $10 a month) and no fee for individual transactions (signature or PIN purchases). The other has a low or no monthly fee and instead charges for certain transactions made using the card. In both of these models, there are often still charges for other transactions (e.g. ATM withdrawals, reloading, etc.). Like card features, prepaid card fees vary a great deal. In addition to monthly and pay-as-you-go pricing models, there are also basic card products with fewer features and lower costs, as well as feature-rich products that often have higher costs. Table 2 shows common fees and their average amounts. Competition and technological innovation have spurred a broad reduction in prices as the industry has matured. Fee Type Explanation Range Comment Activation fee Monthly fee Fee for point-of-sale (POS) transaction using Personal Identification Number (PIN) Fee for POS transaction using signature Fee to activate your card, a sign-up or start-up fee Maintenance, usage, and other fees charged to your account each month Fee assessed at POS for purchases using your PIN, like a debit card Fee associated with purchases made in stores with a signature, like a credit card $0 / $3 to $10 Usually free only with direct deposit $0 to $15 Fees may vary with level of usage or be waived for an introductory period. $0 to $2 $0 to $1 Often cheaper than PIN POS transactions ATM withdrawal fee Withdrawing cash from an ATM $0 to $5 May be higher for international withdrawals Reloading fee Balance inquiry fee Monthly statement fee Cancellation/ refund fees Insufficient funds/ overdraft fee Foreign currency conversion fee Fee charged for adding money to the account where your money is held Fee for information about your available balance Fee for obtaining monthly transaction history Fee for canceling card before contract end, or requesting a partial refund of money loaded onto the card Fee for making a transaction when you have inadequate funds, or for exceeding your limit Fee to convert from another currency during international transactions or travel $0 to $5 Direct deposit is generally free; to load cash is usually $4 $5 per load. $0 to $3 May vary according to how information is requested. Usually free if checked online, by text message, or through an automated phone system. Balance inquiries at an ATM or with a live customer service agent by phone usually incur a fee. $0 to $10 Usually free to obtain online; usually there is a charge to have a paper statement mailed to you. Usually no fee, but sometimes upwards of $180 Read contract carefully to determine if these fees apply. $0 to $3 It is typically not possible to overdraft a prepaid card, but it can happen occasionally. Review contract documents carefully for overdraft conditions and charges. Up to 2% (usually a percentage of total spent) Often a convenient way of getting cash in a foreign country; rates usually are better than conventional money exchanges. 13

14 PART I: PREPAID PRIMER Please note that Table 2 is not comprehensive. Any specific prepaid card agreement may contain fees not listed here. Nonprofits and their clients should review prepaid card agreements (available on the card programs website and in printed form in the cards packaging) carefully to understand the fees associated with any given card. How Do Prepaid Cards Compare with Other Payment Products? Although prepaid cards are similar to debit and credit cards in many ways all three are plastic forms of payment that offer a secure, convenient way to pay for most purchases without carrying cash prepaid cards differ in the following important respects: 1. Access: Debit and credit cards can be significantly more difficult to obtain than prepaid cards, since they may require more identification, ChexSystems 5, or credit checks. 2. Overdraft: Prepaid cards are very difficult to overdraft compared with debit and credit cards, saving consumers who would otherwise incur fees for exceeding credit limits or overdrawing their accounts. Banks often permit debit and credit card transactions to proceed even when there are insufficient funds in the associated account or when consumers exceed their credit limits. In both cases, banks charge overdraft or over-the-limit fees. New rules for overdraft fees go into effect for debit card transactions in late Previously, consumers were often automatically opted in to overdraft coverage without any notification. Under the new rules, consumers will have to actively opt in if they want overdraft coverage. Prepaid card users, however, will almost always have such transactions declined, allowing them to avoid high overdraft fees. In extremely rare instances, prepaid cards can be overdrawn. However, in such cases there may still be penalty fees unless the consumer is otherwise enrolled in an optional overdraft protection feature, if offered (for more on overdraft protection now offered on a limited number of prepaid cards, see the sidebar on page 16). For instance, if the full value of the transaction was not debited in real time (e.g., on airplanes or at flea markets) or all at once, and other purchases were made in the interim, cardholders may exceed their available funds and face a penalty. Tips at restaurants are often debited after the price of the meal is deducted. Similarly, gas stations often charge an initial one dollar fee when consumers pay at the pump and then deduct the remainder of the transaction later. 3. Credit building: Credit cards offer a way to build credit, as repayment information is commonly reported to the major credit bureaus. The relationship between debit cards and credit building is more complex and varies by product and institution. Transactions and payments made with a debit card are not reported to the credit bureaus. However, the financial institution providing the checking account and debit card may monitor account activity as part of its own internal underwriting system to determine a future credit offer. Prepaid card companies are increasingly using internal data on consumers transactions to make credit decisions in a similar fashion. Currently, there are two ways to build credit with a prepaid card: 1) consumers use a short-term loan/line of credit feature (as described in sidebar on page 12), and the card provider reports repayment data to the major credit bureaus; 2) consumers use automatic bill pay, and the card provider reports this activity to an alternative credit bureau such as PRBC, allowing consumers who pay their regular bills on time to establish a record that could be used for future credit or rental applications. 5 The ChexSystems, Inc., network comprises member financial institutions that regularly contribute information on mishandled checking and savings accounts to a central location. ChexSystems shares this information among member institutions to help them assess the risk of opening new accounts. For more information about ChexSystems see 14

15 PART I: PREPAID PRIMER Comparison with Other Transactional Products Prepaid is first and foremost a transactional product that allows consumers to safely store funds and make purchases, so it is useful to think of prepaid in the context of other transactional accounts and services. Table 3 compares key features and qualities of prepaid cards with those of checking accounts (with debit cards), credit cards, and check cashing. Table 3 Prepaid Cards versus Checking Accounts, Credit Cards, and Check Cashing Product Check cashing Prepaid card Direct deposit free if feasible; otherwise still need to cash check Checking account with debit card Direct deposit free, regular check may add delay Check cashing Pay bills Yes Yes No must buy money order Earns interest Rarely Sometimes No No Credit check required No Sometimes. ChexSystems check often required. Overdraft protection and fees Fees Rarely Some combination of monthly fee and some transaction fees Yes, although regulation may make overdraft less common Often no monthly fee, but other fees: for checks, risk of overdraft fees, or minimum balance fees Yes No No Fees (can be high) at time of check cashing Theft protection Yes* Yes No Yes Credit Sometimes No No Yes Builds credit score Yes Limited** No No Yes ID requirements Minimum balance requirements - State-issued ID or passport (some cards accept other foreign IDs) - Social Security number or ITIN*** (not always required because often there is no interest income to report) -Address - State-issued ID or passport - Social Security number or ITIN (not always required) -Address Photo identification only No Yes (usually) No No * MasterCard and Visa currently limit consumer theft liability on prepaid cards to $50, but they are not required by law to do so. Prepaid cards sometimes offer a short-term loan or line of credit (see page 12). ** Sometimes cards report payment of regular bills to credit agencies, which can help to build credit. *** ITIN stands for Individual Tax Identification Number. Credit card No Yes Yes Yes, when credit limits are exceeded Sometimes monthly fee, interest charges, late charges, overdraft charges - State-issued ID or passport -Social Security number - Address 15

16 PART I: PREPAID PRIMER A Note About Wage Garnishments Like other accounts, funds stored on prepaid cards are subject to garnishment. With a checking or savings account, the garnisher typically must send a subpoena to the financial institution to access account records. With prepaid cards, as the funds are stored in a pooled account, the garnisher must subpoena the card provider rather than the financial institution, which can be more difficult. 6 Overdraft Protection on Prepaid Cards Increasingly, prepaid card companies offer overdraft protection to their cardholders, allowing them to make purchases or ATM withdrawals for amounts greater than the balance in their card account. Consumers may opt in to this feature, and fees for this service vary. Some programs offer a buffer or an amount (e.g., $10) that users must exceed before a fee is charged. Some programs also offer a grace period, or a window of time during which consumers can address the overdraft before a fee is charged. Nonprofits serve an important role in helping their clients determine whether overdraft protection will be beneficial to them. 6 See Appleseed s Understanding Prepaid Card Partnerships: A Guide for Nonprofit Organizations in New York,

17 PART I: PREPAID PRIMER The Prepaid Industry The prepaid industry has grown rapidly in recent years. In 2005, approximately $14.7 billion was loaded onto an estimated 45 million network-branded cards. By 2008, that amount had more than quadrupled to $60.4 billion. 7 General purpose, reloadable prepaid cards in particular were used for more than $4 billion in transactions in 2008, and that number is expected to increase to $10.8 billion by A recent FDIC estimate suggests the growing appeal of prepaid cards: 9.7 percent of U.S. households including 11.9 percent of unbanked and 16.4 percent of underbanked households use prepaid cards. 8 The prepaid card industry is young, diverse, and growing quickly. A handful of large companies have the most significant market presence Walmart, H&R Block, Green Dot and NetSpend but a large number of card program managers make up the rest of the card volume. Some companies in this space offer prepaid cards as their primary line of business, while others offer prepaid as an addition to an established core business, such as Walmart, H&R Block, Western Union, Univision, etc. Industry Structure Producing a prepaid card, issuing it to customers, and ensuring its proper operation requires collaboration by multiple companies. There are six distinct functions within the industry: 1. Payment network: The networks (Visa, MasterCard, Discover, and American Express ) provide the electronic channels through which transactions occur. 2. Card issuer: The issuing bank or other depository institution that provides the BIN (bank identification number) for the cards and holds the funds stored on the cards. 3. Fulfillment and transaction processor: The processor facilitates fulfillment and shipment of the cards, processes transactions, and tracks and distributes funds held in the issuing financial institution. Sometimes these services are provided by multiple companies; some companies specialize in fulfillment, while others specialize in transaction processing, though many carry out both functions. 4. Program manager: This entity or person provides the customer interface for the prepaid product and handles the marketing and day-to-day operations of a card program. Program managers can provide fulfillment and distribution services, but more often they contract with other companies for these services. Issuers and processors also may act as program managers, but frequently the program manager is a third party. 5. Loading network: Reload networks allow cardholders to add funds to their cards by giving cash to a merchant at a point of sale. 6. Distributor/Vendor: An entity that distributes and markets prepaid cards to consumers. These six functions come together to reach and serve the customer, as illustrated in Figure 3. 7 Fourth Annual Network Branded Prepaid Card Market Assessment, and Sixth Annual Network Branded Prepaid Card Market Assessment, Mercator Advisory Group, September 2007 and September 2009; and Cardholder Use of General Spending Prepaid Cards, CFSI and Federal Reserve Bank of New York, February FDIC Survey of Unbanked and Underbanked Households, Tables A-13 and A

18 PART I: PREPAID PRIMER PAYMENT NETWORK MasterCard Visa CARD ISSUER MetaBank The Bancorp, Inc. GE Money FULFILLMENT & TRANSACTION PROCESSOR FIS FirstData MT&L FSV Payment Systems PROGRAM MANAGER Account Now GreenDot NetSpend RushCard DISTRIBUTOR/ MARKETER ACE Cash Express Walgreens CVS/pharmacy Walmart Univision Western Union LOADING NETWORKS GreenDot Western Union MoneyGram Visa ReadyLink MasterCard repower Figure 3 Industry Supply Chain Note: The names mentioned in this graphic are examples of companies that serve various functions in the prepaid supply chain. This is not an exhaustive list of all industry players. Although there are six distinct functions, the lines can blur between the functions because some companies are vertically integrated, meaning they perform more than one function in the supply chain. NetSpend is an example of a vertically integrated company. They fulfill and process their own transactions and manage their own programs, but also market and distribute their cards directly to consumers online and through distribution partners such as check cashers and grocery stores. NetSpend also has its own reload network with more than 100,000 reload locations in the United States. Another example is GreenDot, which serves as a program manager, distributor, and cash reload network. 18

19 PART I: PREPAID PRIMER Economic Overview of the Industry To fully educate consumers about prepaid cards and to engage with prepaid card providers, it is important to have a basic understanding of the economics of the industry and how the various players make money. Prepaid cards are generally a low-margin business, meaning profit makes up a small percentage of revenue. Therefore, a relatively small amount of profit must be divided by all of the parties along the supply chain. In addition, the fixed costs in technology, systems, process, and new program setup are relatively high compared with the variable cost associated with adding each new customer. Primarily, this implies that product volume is important for profitability (Figure 4). $ Revenue PROFIT Total Costs (Fixed plus Variable) Fixed Costs (high): Cost to set up systems, relationships, and each card program Variable Costs (low): New cost per each additional cardholder $0 0 Active Cards NUMBER OF ACTIVE CARDHOLDERS Figure 4 Illustrative Cost Structure for Prepaid Card Industry Industry revenue comes from a variety of sources, including: Card fees (as outlined in Table 2) Interchange fees (paid by the merchant to the payment network on each transaction; averages 2 percent of transaction value) Float or interest earned on deposits Ancillary products such as fees and interest earned from short-term loans/lines of credit How the revenue gets divided across all of the players in the supply chain varies by card program. 19

20 PART I: PREPAID PRIMER Legal and Regulatory Issues Because of the prepaid card industry s relative youth, the regulatory system governing prepaid cards is still evolving. Anyone engaged in this space should be aware that regulatory changes may affect product offerings, pricing, features, and consumer protections. Regulators have not yet explicitly extended many important consumer protections such as Regulation E 9 and FDIC pass-through insurance to prepaid cards. However, this does not mean these protections are unavailable indeed most of the major prepaid card providers operate in compliance with these regulations. However, you should carefully screen any product offerings to make sure such protections are included, and advise your clients to do the same. It is important to evaluate a card s terms and conditions, in order to make sure that any and all fees are clearly disclosed and that dispute resolution procedures are straightforward. You should also ensure that basic account transaction information is available, such as through electronic statements. In addition, it is critical to choose a card with FDIC pass-through insurance (which guarantees that each card is insured as an individual account, and its funds are protected in the event that the issuing bank fails). To verify that a card is FDIC insured on a pass-through basis, check with the program manager or card distributor, or contact the issuing bank. To find a card with good terms, fees and resolution procedures, review the disclosures and card contract carefully, and compare multiple card offerings, especially if you intend to refer clients to a specific prepaid card, or distribute cards yourself. Appendix B contains details on some of the legal and regulatory issues affecting distribution of prepaid cards. Be sure that your contract with a card issuer addresses these concerns and answers them to your satisfaction. For more information on these and other regulatory issues, please refer to CFSI s policy brief on prepaid card regulation, forthcoming in late Regulation E implements the Electronic Fund Transfer Act, which establishes guidelines for account disclosures, error resolution procedures, periodic statement requirements, and more for accounts involving electronic transactions. Payroll card accounts are subject to Regulation E. Most issuers of GPR cards offer Regulation E types of protections to cardholders, in addition to the card brands zero-liability policies. 20

21 PART I: PREPAID PRIMER Benefits and Issues for Consumers 10 It s like a weight is being lifted off my shoulders knowing that I don t have to carry money on me. When I used a bank, every time I was turning around I was being charged for this or billed for that. With my prepaid card, there is none of that. I know how much I spend a month to use it, and that s all there is. What does this mean for the people your nonprofit serves each day? It means that prepaid is a potentially beneficial product choice for consumers looking to conduct financial transactions and that you should consider how to best integrate prepaid cards into your organization s programming. Prepaid cards are increasingly being marketed to and used by consumers as an entree to or a substitute for a traditional checking account. Given the variation in consumers financial services needs and preferences, prepaid may not be for everyone. However, for many underbanked consumers, it can be a great option in helping them meet their short-term needs and possibly in achieving longer-term savings and credit-building goals. To better understand how cardholders view their cards and the benefits cards offer, CFSI conducted in-depth interviews with prepaid card users. The points below summarize the benefits they described. Reduced cost for financial services: Prepaid cards can reduce the cost of basic financial services for people who have access to direct deposit (either through an employer or government benefit). This is particularly true when the alternative is paying for check-cashing and bill-payment services, or using a checking account and incurring overdraft or insufficient-fund fees. CFSI s June 2009 paper One Size Does Not Fit All: A Comparison of Monthly Financial Services Spending 11 contains several case studies comparing prepaid card fees to the cost of check cashing or checking accounts. One of these examples is summarized in the sidebar titled Potential Cost Savings with Prepaid (page 23). Using online bill pay, free balance-inquiry methods (text message, online, etc.), and receiving cash back with purchases to avoid ATM fees can also help to keep the costs of the prepaid card low. Security: Prepaid cards allow consumers to make purchases and pay bills without carrying large amounts of cash. Immediate liquidity: Funds directly deposited onto prepaid cards are available immediately, making prepaid an appealing tool to consumers who typically use check cashers because they cannot afford to wait for a financial institution to clear a deposit into a checking account. I m deeply grateful for my prepaid card. I can buy online; I can do anything that a person with good credit can do. 10 Except where otherwise noted, the findings described in this section are from the study conducted in A Tool for Getting by or Getting Ahead? Consumers Views on Prepaid Cards, CFSI with Jennifer Romich and Eric Waithaka, April Available at Consumer quotes are excerpts from A Tool for Getting by or Getting Ahead? Consumers Views on Prepaid Cards, CFSI with Jennifer Romich and Eric Waithaka, April 2009, and Satisfaction with and Usage of Prepaid Cards, NBPCA/CFSI Survey Results, April

22 PART I: PREPAID PRIMER I m not a bank or credit card type of person. Reloadable prepaid cards give me the ability to make purchases. I rent a car with it, and that s major. I think it is more socially acceptable to own/use a credit card, and by using a prepaid card I feel more socially acceptable. Transparency and predictability: Fees for transactions and deposits are charged upfront for prepaid cards. The cards are difficult to overdraft and tend to have fewer back-end charges than checking accounts. Almost three-quarters of prepaid card users say the fees for using their cards are fair, and an even greater percentage say they understand the fees well. These numbers increase even further for consumers who use the cards regularly. 12 Convenience: Consumers can make purchases and access funds at any location that accepts the network brand (e.g., Visa or MasterCard ) and all hours of the day. Prepaid cards allow customers to make purchases and pay bills online. Accessibility: Many underbanked consumers either do not have, or do not perceive themselves as having, sufficient identification or credit history to open a traditional checking account at a financial institution. Prepaid cards do not require a check of consumers files with the credit bureaus or ChexSystems, a reporting agency that catalogs negative bank account actions such as bounced checks and fraud. Acceptance/Inclusion: Having a card gives customers a way to pay that does not differentiate them from other consumers who may be more financially advantaged. Whereas using a money order is a visible sign of not having a checking account, the prepaid cards act and look like credit or debit cards. Financial discipline: Prepaid cards help consumers limit spending and stay on budget. People can only spend what they have, so it is hard to overdraft or get into debt. Build savings: Prepaid cards can help people build savings, particularly if the card has a linked savings account with automated deposit and/or a competitive APY. I primarily use reloadable prepaid cards for items like gas, groceries, and smaller bills like phone or Internet services. It s easy to place the money into the account during the month and stay within the confines of the budget I have allotted to spend for these goods and services. 12 Satisfaction with and Usage of Prepaid Cards, NBPCA/CFSI Survey Results, April

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