The Food Marketing Institute1 (“FMI”) and the members that we represent appreciate the opportunity to respond to the Federal Reserve System’s Board of Governors (“Board” or “Fed” )request for comments on the proposed rule to amend Regulation E in regard to the treatment of prepaid products, primarily gift cards, as directed by the Credit Card Accountability, Responsibility, and Disclosure Act of 2009. 74 Fed. Reg. 60986 (November 20, 2009).
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