Updates
8/9/2010
New Compliance Burdens for Gift Cards and Consumer Promotions: The CARD Act Creates New Requirements and New Liabilities
Nearly every company that sells a gift card or provides promotional benefits to consumers will – as of August 22, 2010 – need to comply with the CARD Act. But what is the CARD Act and how will it affect your loyalty programs and your gift cards?
The Credit Card Accountability, Responsibility and Disclosure Act of 2009 (CARD Act) sounds like one more consumer credit regulation, but almost any business that uses modern technology to interface with consumers needs to pay attention. In fact, the CARD Act covers gift cards, gift certificates and, to the surprise of many, offers and rewards from promotional programs (e.g., certain online coupons and sweepstakes prizes) and/or loyalty programs (e.g., programs awarding customers “$10 off” coupons or cards after spending a certain amount of money at a particular store). The CARD Act imposes disclosure requirements on offers and rewards from promotional and loyalty programs, and implements both substantive requirements and disclosure requirements for gift cards, gift certificates and the like.
Click on the PDF link above to view the full alert.
The Credit Card Accountability, Responsibility and Disclosure Act of 2009 (CARD Act) sounds like one more consumer credit regulation, but almost any business that uses modern technology to interface with consumers needs to pay attention. In fact, the CARD Act covers gift cards, gift certificates and, to the surprise of many, offers and rewards from promotional programs (e.g., certain online coupons and sweepstakes prizes) and/or loyalty programs (e.g., programs awarding customers “$10 off” coupons or cards after spending a certain amount of money at a particular store). The CARD Act imposes disclosure requirements on offers and rewards from promotional and loyalty programs, and implements both substantive requirements and disclosure requirements for gift cards, gift certificates and the like.
Click on the PDF link above to view the full alert.
The material contained in this communication is informational, general in nature and does not constitute legal advice. The material contained in this communication should not be relied upon or used without consulting a lawyer to consider your specific circumstances. This communication was published on the date specified and may not include any changes in the topics, laws, rules or regulations covered. Receipt of this communication does not establish an attorney-client relationship. In some jurisdictions, this communication may be considered attorney advertising.
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