Asking consumers to declare the funds on their prepaid cards when they cross borders is a burdensome and misguided regulatory effort that places unfair requirements and imposes unequal treatment on prepaid cardholders, while at the same time fails to effectively prevent the criminal money laundering activity it is set up to combat. There are many kinds of prepaid cards, but "general use" prepaid cards are devices that offer an alternative to checking accounts by providing consumers - especially those that are unbanked - access to the financial system. As with debit cards, such prepaid cards are access devices issued by a regulated financial institution that access funds held at financial institutions. Unlike true monetary instruments that are generally anonymous and transferable, users of payroll and general purpose reloadable (GPR) prepaid cards have their identities collected and verified in accordance with the Bank Secrecy Act. Just like a debit card, a prepaid card can have funds automatically loaded on it from a third party source such as an employer or a government program while the card is still in the user's wallet or purse. Possessing the card does not control the funds. Consumers who travel with credit or debit cards are protected by the Right to Financial Privacy Act. They have no obligation to report their bank account balances or size of credit lines. We believe that treating prepaid cardholders inequitably versus those with credit cards and bank accounts is both unfair and it violates their financial privacy. We are also concerned that the new prepaid card readers at US borders will not be effective at preventing financial crimes. Criminals with reloadable general use prepaid cards (which require ID verification) could cross the border with a prepaid card with a small sum loaded on it, truthfully declare that they are not carrying more than $10,000 on the card, and then remotely add additional funds onto the card after they arrive at their destination, just as could happen with debit cards. The NBPCA believes that this regulatory effort, while well intentioned, will penalize law-abiding citizens who use prepaid cards as their primary tools to budget and manage their finances and will do little to deter the criminals they are trying to catch. It should be reconsidered and NBCPA looks forward to additional discussions with law enforcement in meeting our joint goal of stopping the abuse of prepaid cards by fraudsters.