What laws apply to companies that wish to issue their own prepaid cards?

  • The cards can only be used to buy goods/services from the company
  • The cards are refundable, and the remaining balance can be returned.
  • I like this question, but I think it needs a little more detail on jurisdiction. This is likely to be something where jurisdiction really does matter. In some jurisdictions, prepaid cards might be considered securities which need to be registered and/or follow local securities and/or banking law, such as accounting requirements or collateral requirements. Commented Jan 21, 2023 at 13:39
  • Thank you, @RobertColumbia. I am interested in NJ, US laws, and the US. Commented Jan 22, 2023 at 4:39
  • The cryptocurrency question and the prepaid card question are petty much entirely separate and should be broken into separate questions.
    – ohwilleke
    Commented Jan 22, 2023 at 20:51
  • @ohwilleke got it. I removed the cryptocurrency question Commented Jan 22, 2023 at 23:24
  • It seems like you're basically asking whether a company can offer refundable, rechargeable gift cards. Is there more to it than that? Commented Jan 23, 2023 at 13:15

1 Answer 1


No permit is required. The NJ law that applies is the same in substance as the federal laws, under which this is a "store gift card" or "gift certificate" depending on whether it can be re-filled. It is not a "general-use prepaid card" because it can only be used with the company and affiliates, and cannot be used generally. Regardless of the specifics of the card, 12 CFR Part 1005 as linked above is the set of federal regulations that you would have to comply with. There are relatively few distinctions between the classes of cards, the main requirement being that you cannot mislabel a card that is of one type as being a card of another type; see here for cards that are not "general-purpose".


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