Ensuring Financial Inclusion and Regulatory Balance in Prepaid Contributions

The Innovative Payments Association (IPA) has submitted a comment letter to the Federal Election Commission (FEC) addressing a proposed rulemaking related to contributions made using prepaid cards. While we recognize the importance of maintaining transparency in campaign financing, the IPA emphasizes that prepaid cards are already issued by highly regulated entities and are subject to stringent compliance under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) requirements.

Prepaid accounts play a critical role in financial inclusion, offering millions of unbanked and underbanked Americans access to secure and efficient financial tools. These accounts are particularly valuable for individuals and government programs, delivering faster and safer transactions than traditional methods. The proposed amendments could inadvertently stigmatize these essential tools, limiting their use and impact.

Key Points from the IPA's Comment Letter:

• Prepaid accounts are issued by regulated institutions and comply with comprehensive BSA/AML requirements.
• Reloadable prepaid cards offer transparency and security, with tracking mechanisms comparable to debit and credit cards.
• Millions of Americans rely on prepaid accounts for their everyday financial needs, including political contributions.
• Government programs, such as the U.S. Treasury’s Direct Express initiative, have successfully adopted prepaid tools to improve efficiency and cost-effectiveness.

​We encourage you to read the full comment letter to explore how the existing regulatory framework addresses concerns raised in the petition, ensuring prepaid accounts remain a trusted and inclusive financial tool.

Download Comment Letter