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#360802 - 05/18/05 04:32 PM MSB Letter
I Wear Many Hats Offline
Platinum Poster
I Wear Many Hats
Joined: Mar 2001
Posts: 591
the beautiful state of ME
Does anyone have a form letter they could share that could be sent to a customer that is an unregistered MSB. This customer operates a convenience store and cashes checks. The only account they have with us is the account where they deposit the checks they cash for customers and then withdraw cash to fund the next day's round of checks. At first glance, I cannot verify that they cash more than $1000 in checks for any one person, but it certainly is a probability. I would like to send them a letter stating that if they don't register as a MSB and provide proof of registration we will close their account. Just hoping not to reinvent the wheel. Email is susan.norton@the1st.com if you have anything.

Thanks
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#360803 - 05/19/05 11:48 AM Re: MSB Letter
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Dear Customer,
A review of your account with us indicates that you are cashing checks for your customers.
State regulations require that under these circumstances you must be registered as an MSB.
Please send us a copy of your MSB registration form as well as your Check Casher license no later than 14 days from the date of this letter.
For your convenience I have included a link to FinCEN's recent guidance for MSBs,(include link).
Please be advised that if you are unable to provide this documentation, we will have to close your accounts.
Please feel free to call me to discuss these requirements.
Sincerely,
Bank Officer

Hope this helps you.

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#360804 - 05/20/05 04:51 PM Re: MSB Letter
dare2dream Offline
100 Club
dare2dream
Joined: May 2005
Posts: 128
California
I really like your letter, it's short and to the point.

One suggestion - while short and to the point is great for those of us who know the requirements and regulations (within reason), one of the things I ran into was that a lot of my MSB's and potential MSB's had no knowlege of the requirments/laws/etc.

Now they get this letter, and they basically get really concerned because the words "close your account" are in it. We had a couple end up registering that didn't need to and are now required to do a lot of things they really didn't need to do. As well as, I have the following question:

State licensing? AML programs? What other types of things do you guys ask for when identifying MSB's in your current portfolio?

Thanks!
Lynda
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#360805 - 05/20/05 05:29 PM Re: MSB Letter
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
In the letter, you can reword to say, "If you are unsure of your status, please go to www.msb.gov and view the regulations."
What I ask for depends on the size of the relationship, but at the very least I would get a copy of the MSB registration, the Check Casher license and the occupational license from the city or county.
I also get a copy of their AML policy.
If they cash checks payable to a corporate I review the files that they maintain on those corporations.
For risk purposes and expected activity, I request three months bank statements so I can see the volume of returned items, average balances, cash orders etc.
Hope this helps you.

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#360806 - 05/20/05 05:45 PM Re: MSB Letter
dare2dream Offline
100 Club
dare2dream
Joined: May 2005
Posts: 128
California
that does. We also ask for 2 years financial statements, and then our credit department reviews them for "stability" and "credit worthieness" to see if there may be trouble going down the road.

Does anyone else go to these depths? I'm just curious since this is still really new to me and I want to do the right thing, but not kill these follks in the process.
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The trouble with real life is that there is no danger music.

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#360807 - 05/20/05 09:02 PM Re: MSB Letter
Dolly Nugent Offline
Diamond Poster
Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
We don't review financial statements, but we do look at the activity and determine if a certificate of deposit is warranted to cover potential charge backs.
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CRCM
Opinions expressed are my own.

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#360808 - 05/23/05 11:59 AM Re: MSB Letter
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
We ask for two years financials and tax returns also.
And we establish a CD as collateral against returned items.

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#360809 - 05/23/05 08:48 PM Re: MSB Letter
Anonymous
Unregistered

make sure legal is OK with whatever you send out

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#360810 - 05/23/05 09:54 PM Re: MSB Letter
ComplianceO Offline
Junior Member
Joined: Apr 2005
Posts: 47
Northern CA
We request a copy of their registration letter from FINCEN and also require them to complete a questionaire that basically asks them about their activities and about what kind of Anti-money laundering procedures they have, what procedures they have in place for Bank Secrecy Act, Suspicious Activity monitoring and reporting, etc.

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#360811 - 05/26/05 07:11 PM Re: MSB Letter
Anonymous
Unregistered

I have been working on a questionaire but am having a few problems. Do you mind sharing? I can give you my e-mail if you say yes.

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