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#351582 - 04/26/05 05:36 PM MSB Guidance-Issued, finally
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#351583 - 04/26/05 06:06 PM Re: MSB Guidance-Issued, finally
Pinkie CRCM Offline
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Anyone have comments on it?

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#351584 - 04/26/05 06:28 PM Re: MSB Guidance-Issued, finally
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It answers some questions but not all questions. I particularly like the examples of lower risk indicators and higher risk indicators. I like the bulleted lists instead of legalese.

It also holds out the carrot of "...the forthcoming interagency Bank Secrecy Act/Anti-Money Laundering examination procedures."

Frankly, when you read the material that has been prepared for MSB's .... it is pretty overwhelming. Imagine the Mom & Pop grocery store that has cashed checks for years.

I'd like to reserve additional comment for when I've had a chance to really digest it.
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#351585 - 04/26/05 06:38 PM Re: MSB Guidance-Issued, finally
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#351586 - 04/26/05 06:55 PM Re: MSB Guidance-Issued, finally
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Oops, sorry, didn't see that someone already posted a thread about it. Please see other one so there aren't 2 going.

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#351587 - 04/26/05 07:12 PM Re: MSB Guidance-Issued, finally
Anonymous
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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.

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#351588 - 04/26/05 07:23 PM Re: MSB Guidance-Issued, finally
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