Prepaid / Gift Card Program — impact tolerance ≤ 4 hours — ITOL

Impact tolerance: ≤ 4 hours — any time, for authorization/POS processing; same-day for balance/dispute resolution (illustrative default — trace the derivation, then replace with your own harm analysis)

Definition: Issuance and processing of general-purpose reloadable prepaid cards and closed/open-loop gift cards. Designated only above a materiality threshold (≥ $25M in outstanding prepaid balances). Below that, harm concentrates in the program manager, and the service is mapped as a card-processing dependency.

Why it is designated: The CFPB's Prepaid Accounts Final Rule extends Reg E error-resolution and Reg Z-like disclosure protections to prepaid accounts. Reg E's gift-card provisions (12 CFR § 1005.20) add specific fee and expiration rules. Together they treat prepaid as a near-real-time payment instrument on consumer-protection clocks similar to debit cards.