Defending the Integrity of Prepaid Products Amid Election Concerns

​The Innovative Payments Association (IPA) submitted a comment letter to the U.S. Treasury in response to the Presidential Memorandum investigating potential unlawful foreign contributions in U.S. elections. While the memo raised concerns about the use of prepaid products for “straw donor” schemes, the IPA urged Treasury and the DOJ to rely on the existing, rigorous anti-fraud and compliance frameworks already governing these products.

“Prepaid accounts are highly regulated and provide full transaction traceability,” said IPA President and CEO Brian Tate. “They are not a loophole but a lifeline for millions of Americans managing their financial lives.”
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IPA emphasized that prepaid accounts comply with Bank Secrecy Act (BSA/AML) requirements and support financial inclusion, especially for unbanked and underbanked communities. Rather than overcorrecting, the letter calls for informed policy rooted in the realities of how these products work.

Download Comment Letter