1. I'm glad the guidance clarified that our due diligence can be limited if the risk is low. That just makes sense. As often as we complain about regulations, I think they should be applauded for doing it right this time.
2. We've gone back and forth about whether a customer who cashes one check over $1,000 is then an MSB forever and ever; therefore, they have to register. I've been particularly interested in this. I think FinCEN knew banks were confused about this, and although they don't specifically address this scenario, I think they are saying these types of customers have to register.