Compliance Blog

Nov 27, 2007

Gift Cards

Yesterday, the OCC released what appears to be their annual "consumer alert" regarding gift cards.  Access the press release here.  You can access the consumer tips here.  The Compliance Guy plans on sending this to his friends and relatives this holiday season, as it is full of useful, consumer-centric tips about fees, disclosures, and the like.

But what about guidance for credit unions that wish to offer gift cards to their membership?  There isn't all that much guidance on the issue.  Gift cards are partially regulated by Regulation E.  The Federal Reserve, however, has not issued a regulation that governs gift cards specifically.

In August 2006, the OCC issued guidance for national banks to consider when offering gift cards.  Read a press release about the guidance here.   Read the guidance here.  OK, so it isn't from NCUA.  Fine.  But the OCC Bulletin raises good issues and gives good guidance in the area.  I certainly would read it before offering gift cards.  But that's just me.