It is always interesting to compare the perspective of industry trade groups with those of consumers, consumer advocates, and legislators.  Take for instance this article, which talks about the new gift card rules and their effect on the prepaid card industry.  The article quotes the Network Branded Prepaid Card Association.

By the NBPCA‘s estimate, more than 90 percent of prepaid gift cards are drained of funds within a month after they are purchased.

Really?  How then can breakage exist at a level of 10% of the face value of these cards?  This also goes against a common sense experience of prepaid gift cards, which is that it is VERY VERY HARD to completely use them up, due to the fact that so few merchants understand how to do a split tender transaction or have the ability to determine the remaining balance on a card.