Oh, Chris, perhaps I wasn’t clear about why Rob insisted the imaginary gift cards were real…
In the money transmitter regulations of many states, in store gift card schemes are specifically exempted from licensing requirements, provided that certain conditions are met.
The entire thing was a pretense to represent to regulators that Masterbucks was simply an in-store stored value system.
I will post the relevant state regulatory materials later, but this letter is a determination letter from the US financial crimes enforcement network discussing whether a mall-wide gift card scheme constitutes a money services business:
https://www.fincen.gov/index.php/re...definition-money-transmitterstored-value-gift
Now, long story short, while a stored value card looks like a debit card, the usual difference is that a gift card scheme is subject to various limits, cannot be broadly used, and , most certainly cannot be a vehicle for balance transfers from one person to another.
But despite the limitations on the gift card exception, and the fact that Masterbucks did not meet those limitations, someone at Epik thought it was a brilliant idea to try to characterize it as a gift card scheme.
That was the point of the discussion there - Rob Davis was peddling the fiction that Epik was in the gift card business as the silver bullet exception from licensing requirements for money transmitters. I guess I could have made that clearer.
