The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, National Credit Union Administration, Office of the Comptroller of the Currency and U.S. Department of the Treasury’s Financial Crimes Enforcement Network (collectively, the “agencies”) published Interagency Guidance to Issuing Banks on Applying Customer Identification Program Requirements to Holders of Prepaid Cards. The guidance clarifies prepaid card customer identification program (CIP) requirements, including those cards sold and distributed by third-party program managers but issued by the bank and for which the bank processes transactions, as well as cards that are used to provide employee wages and health care and government benefits. The guidance refers specifically to prepaid cards, but the agencies explain that it also applies to other prepaid access products that meet the guidance’s criteria, including products offered through mobile phones. According to the guidance, a bank should apply its CIP to the holders of certain prepaid cards issued by the bank by, first, determining whether an account is created and, second, identifying the customer.