In that case the card effectively is a bank account of its own and often has features such as accepting direct deposit. I believe those cards are regulated as R

In that case the card effectively is a bank account of its own and often has features such as accepting direct deposit. I believe those cards are regulated as Reg E (EFT/debit) and not Reg Z (credit). They aren't regulated as banks, though a lot of them do place the money with a bank to get FDIC protection, but there was a major regulation change for these accounts a few years back that added more requirements for fee disclosure and ID verification.