As always there will be loopholes to the protections offered by the Credit Card Act of 2009 that card issuers will try to exploit. One such loophole, chronicled here, is that reloadable cards that are not marketed as gift cards are exempt from the provisions of the regulations under that act, which makes no sense considering those are more like credit cards which are the main focus of that legislation anyways. With this loophole, look for prepaid open-loop (Visa) gift cards to be instead convereted into reloadable cards that don’t say gift on them.