The Federal Reserve Board's proposal to regulate stored-value cards should concern bankers. Under the March 20 plan, the Fed made a distinction between "off-line accountable" and "off-line unaccountable" stored-value cards.

The Fed determined that the off-line accountable cards are subject to the Electronic Funds Transfer Act, or EFTA, and can therefore be subjected to Regulation E. However, off-line unaccountable cards do not fall within the scope of EFTA. This distinction will cause unnecessary regulatory and pricing disparity between the different card models.

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