Proprietary and Confidential June 13, 2012 Compliance Overview: Gift Card, Promotional Card, and Incentive Card Program National Restaurant Association.

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Proprietary and Confidential June 13, 2012 Compliance Overview: Gift Card, Promotional Card, and Incentive Card Program National Restaurant Association

Proprietary and Confidential | © 2010 Card Compliant, LLC About Card Compliant Card Compliant, based in Kansas City, is a compliance specialty company serving the prepaid access and card industries. It addresses niche subjects, providing technology-supported solutions to the regulatory, legal and accounting challenges encountered in card programs. It engineers compliance at the design, implementation, and operational phases of a card program to enhance program value and reduce noncompliance risk. Solutions combine patent-pending technologies and business methods implementing compliance on a per card basis. Visit Card Compliant at 2

Proprietary and Confidential | © 2010 Card Compliant, LLC Introductions Overview Questions 3

Proprietary and Confidential | © 2010 Card Compliant, LLC Regulatory Challenge Regulation Complexity Escheat Statutes:50 States Consumer Statutes:Federal and 50 States AML:Federal Anti-Money Laundering Rules, OFAC Licenses:Federal (FinCEN) and States (Money Transmitter) Privacy:Federal and some States Income Tax:Special IRS Rules on Tax Recognition Income Tax:Special IRS 1099 Requirements Activity Taxes:5 States GAAP Accounting:US and International Standards SEC:Earnings Recognition Rules The FedsThe States FED FTC CFPB IRS Attorney General FinCEN Treasurer 4

Proprietary and Confidential | © 2010 Card Compliant, LLC Agenda 5 Topic Areas – Consumer Protection Laws – Unclaimed Property Laws – Income Tax Regulations – GAAP Accounting Standards – Anti-Money Laundering Regulations Ten Current Hot Compliance Issues 5

Proprietary and Confidential | © 2010 Card Compliant, LLC Consumer Protection Laws Regulators – State Laws – The Federal Reserve – FTC – CFPB Fees Expiration Dates Cash Back Disclosures 6

Proprietary and Confidential | © 2010 Card Compliant, LLC Unclaimed Property Laws Regulators – State Laws Restaurant Solutions 7

Proprietary and Confidential | © 2010 Card Compliant, LLC Income Tax Regulators – IRS Taxation upon Load 1 Year and 2 Year Deferrals Impact of Escheat Solutions 8

Proprietary and Confidential | © 2010 Card Compliant, LLC GAAP Accounting Standards Regulators – FASB – IASB – SEC GAAP Rules Derecognizing Card Breakage 9

Proprietary and Confidential | © 2010 Card Compliant, LLC Anti-Money Laundering (AML) Regulation Regulators – FINCEN New FinCEN Regulation Closed Loop Exemption 10

Proprietary and Confidential | © 2010 Card Compliant, LLC Current Hot Compliance Issues New Jersey Escheat Colorado Escheat Cash Back Expiration Dates on Promotional Cards FinCEN Update FinCEN and Your B2B Cards FASB Guidance Taxed Incentive Cards Personally Identifiable Information Consumer Financial Protection Bureau 11

Proprietary and Confidential | © 2010 Card Compliant, LLC Conclusion The webinar is complete. Thank you for attending. Card Compliant is proudly endorsed by the NRA and has maintained a strong partnership for several years. For additional information on optimized compliance solutions, please contact Card Compliant at