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16 maintains. In this regard, Delaware argues that the Disputed Instruments do not implicate the concerns underlying the FDA because the banks that sell the Disputed Instruments generally do keep adequate records, and therefore States can avoid the escheatment problem by passing laws requiring those banks to transmit their records to MoneyGram and requiring MoneyGram to keep those records. But the FDA regulates escheatment, so it is the recordkeeping practices of the entity holding the funds that is relevant. Here, that entity is MoneyGram, not the banks. MoneyGram has the recordkeeping practices identified as warranting intervention through the FDA, see §2501(1), and the statute contains a solution to the escheatment problem that MoneyGram’s ordinary business practices cause, see §2503.

Finally, Delaware suggests that §2503 must be read narrowly in order to avoid both creating surplusage and sweeping in all sorts of financial products that Congress did not intend to cover. This goes too far. Although Delaware argues, with some merit, that broadly defining a “money order” as a prepaid instrument used to transmit money to a named payee would render the statute’s separate references to “traveler’s checks” and “other similar written instruments” superfluous, we need not define “money order” in order to conclude that the FDA applies to the Disputed Instruments, since it suffices that the instruments in question be “similar” to a money order; they need not share its definition. And if “other similar written instrument” is interpreted with reference to both the inherent qualities of a money order and also the recordkeeping concern that the FDA expressly identifies in the text, as discussed above, then the scope of the statute is properly cabined.