Propose: Closed- vs Open-Loop Classification #36
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Topic: Closed- vs Open-Loop Classification
Whether stored value is clean store credit or a regulated money-transmission instrument turns on a single line: does value move only among commonly-owned storefronts, or between unaffiliated owners? This RFC defines that closed- versus open-loop classification, keyed to common ownership rather than storefront count. It documents the regulatory line the two-tier model rests on — it does not clear it, which remains a legal matter for counsel.
On-behalf-of: Ben Stull <ben.stull>