The Australian Securities and Investments Commission has approved the most extensive mail-out of unsolicited MasterCard and Visa products in Australia's history, giving the issuers relief from a law that could have blocked the campaign. Compliance Complete has discovered that ASIC has given regulatory relief to Australia's two largest airlines — Qantas and Virgin Australia — regarding their plans to send millions of unsolicited prepaid debit cards to their frequent flyer member bases.The Qantas mail-out alone could see more than one-third of the Australian population receiving an unsolicited Qantas Cash product in the mail, including children aged between 16 and 18. This is despite the fact that section 12DL of the Australian Securities and Investments Commission Act 2001 specifically outlaws the provision of unsolicited credit and debit cards to consumers. In Virgin's case, the unsolicited cards are going out to all eligible Velocity members aged 18 or older.Consumer advocates and financial services lawyers have been stunned by the regulator's decision to give the airlines the go-ahead to launch their unprecedented prepaid debit card campaigns. They said that although the card mail-outs were likely to breach s12DL, ASIC's apparent decision to provide no-action letters to the airlines meant the matter was unlikely to go before the courts.The card issuers, meanwhile, are using semantics such as "prepaid cards", "loading funds" and "online applications" to try to circumvent the obligations regarding debit cards in the ASIC Act. This is despite legal opinions that "prepaid" cards are a sub-set of debit cards; the act of "loading" funds on to the card is akin to transferring funds into a personal account; and the "application" process is a euphemism for quick online activation.In its product disclosure statement, Qantas has alternately described the card activation process as an "application" in some instances, and as "activation" in others. The web address for the "application process" is www.qantascash.com/activate, which consumer advocates have said is a further indication the product issuer is paying lip service to the application process.The Qantas Cash and Virgin Global Wallet products are examples of the new two-sided frequent flyer cards that airlines are launching in conjunction with their partners in the banking and payment card industries. In the case of the Qantas Cash MasterCard product, the Australian Financial Services licence holder and product issuer is Heritage Bank, in Toowoomba, Queensland. The AFSL holder for Virgin Australia's Visa Global Wallet product is Rev Australia, a subsidiary of the US-based payments software company Rev Worldwide.Both Qantas and Virgin have positioned the cards as upgraded loyalty cards, with the financial product embedded on one face of the new chip-and-PIN-enabled membership cards. When consumers turn their membership card over it looks like a traditional Visa or MasterCard facility, including a credit card scheme logo, card number, CVC, chip functionality and signature strip.The main concern with these products is that they are being sent out, unactivated, to frequent flyer scheme members without their "opt-in" consent. The airlines argue that the cards can simply be used as a frequent flyer card if the