Palmer described several distinct types of prepaid card value propositions, each with its own set of operational needs and customer servicing requirements. In addition, Palmer described new roles that exist in prepaid card programs that are not present in traditional credit and debit card programs. He emphasized that the variety of these programs’ requirements and the breadth of third-party participants create complexities not only in the servicing of these accounts but also in the economics of these programs and the regulation of this payments category.

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