Synovus Financial Corporation
From: Michael Smith [mailto:michaelsmith@synovus.com]
Sent: Thursday, July 15, 2004 4:10 PM
To: Comments
Subject: RIN 3064-AC80
July 15, 2004
Robert E. Feldman
Executive Secretary
Federal Deposit Insurance Corporation
55017th Street, NW
Washington, DC 20429
Attention: Comments/Legal ESS
Re: Proposed Stored Value Card Guidance Dear Mr. Feldman, This letter is submitted on behalf of Synovus Financial Corp. (hereinafter "Synovus") in response to the notice of proposed rulemaking "Definition of 'Deposit'; Stored Value Cards" dated April 16, 2004 (hereinafter "Proposed Rule.). Synovus is a $22 billion financial services holding company based in Columbus, Georgia. Synovus provides banking and financial services through 42 affiliate banks and other Synovus offices in Georgia, Alabama, South Carolina, Florida and Tennessee. We appreciate the opportunity to comment upon the Proposed Rule. We join other commenters in urging the FDIC to consider carefully the policy implications of the Proposed Rule giving special weight to promote market innovation. As these points have been sufficiently covered in other letters, we do not repeat them. We do wish, however, to address the Proposed Rule's definition of 'stored value card.' We note that both in the Supplementary Information and in the proposed definition itself, the assumption apparently is made that a physical, tangible card is involved. This is not always the case, as with 'virtual' or on-line 'cards.' In some versions of this business model, the customer receives only an account number after logging on to a website. The account can then be used for internet purchases*but not for in-person purchases. We respectfully submit that the Proposed Rule should specially address whether it applies or not to virtual cards. We are not aware of any policy served by the current ambiguity. Very truly yours,
Michael D. Smith
Senior Vice President
Deputy General Counsel
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