Gift-card / stored-value compliance (CARD Act)

Description

The federal CARD Act of 2009 set the operating envelope for gift cards and stored-value products in the US, and most of the operational work is in the corners that the headline rules do not obviously cover. Headline rules: a five-year minimum validity period from the date of issuance (or the most recent reload, whichever is later), a strict cap on inactivity fees (no fee at all in the first 12 months of dormancy, then at most one fee per month, with prominent disclosure on the card and packaging), and a prohibition on dormancy fees that effectively erode the balance faster than the validity period extinguishes it. The corners are where platform credits, virtual currency, in-game wallets, and refer-a-friend balances live, because the statutory definition of stored value is broader than most product teams assume. A platform credit that is redeemable for goods or services from the issuer but not transferable to others may still count as a stored-value product depending on how it interacts with the cash economy, and the analysis is fact-specific enough that the safe pattern is documented classification at product-launch time rather than retrofitted. CARD Act Section 301 separately bars the issuance of credit cards to consumers under 21 absent a co-signer or independent ability to pay, which catches youth-targeted financial products in unexpected places. State laws frequently layer additional escheatment and unredeemed-balance rules on top of the federal floor.

Applicability

Applies when: markets include US.

How predicates are evaluated

Required by (1 regulation)

• CARD Act

  Credit Card Accountability Responsibility and Disclosure Act of 2009: 5-year validity minimum, inactivity fee restrictions, fee disclosure on packaging, underage credit issuance restrictions, marketplace gift-card analysis.

  15 U.S.C. §§ 1637, 1666i-1, 1666i-2

Fulfilled by (6)

• tango-card · full · low effort · $$
  Tango (Rewards Genius) handles CARD Act expiry / fee compliance for distributed gift-card programs.
• tremendous · full · low effort · $$
  Tremendous gift-card API enforces CARD Act expiry + inactivity-fee rules out of the box.
• blackhawk-network · full · medium effort · $$$
  Blackhawk's distribution + redemption infrastructure handles state-by-state CARD Act + complementary state laws.
• givex · full · medium effort · $$
  Givex stored-value platform with regional fee / expiry controls.
• square-gift-cards · full · low effort · $
  Square Gift Cards built-in CARD Act compliance for SMB merchants.
• In-house build · high effort
  In-house stored-value systems need expiry-clock service + inactivity-fee guardrail + state-law overlay (some states require longer than 5 years).

ClearLaunch does not accept payment from vendors. Methodology.

Evidence formats

• gift-card terms of service citing CARD Act provisions
• fee-disclosure copy on packaging / digital purchase flow
• stored-value classification memo for platform credits / virtual currency
• underage-issuance flow documentation (age check + ability-to-pay verification)
• annual audit log of expiry / fee compliance