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#366958 - 06/02/05 02:10 PM MSB - check cashing
Anonymous
Unregistered

I seem to recall seeing something about this before but cannot find it

we have a customer that was cashing checks over $1,000 and says they stopped but we have proven that they are still doing it, only less often then before.

if they are still cashing we agree that they have to register but if the do truly stop do they have to register???

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#366959 - 06/02/05 02:44 PM Re: MSB - check cashing
Anonymous
Unregistered

I just talked to Fincen about that - their opinion - if they truely stop they would no longer be an MSB but are still a non bank financial institution (NBIF) which generally do make them a higher risk but not subject to Fincen. But, just because Fincen feels that way - it may not be the direction you regulator will take.
We've had a lot of discussion on MSB's and I try to run my questions by Fincen (they are real good about calling back when you leave a message w/ your question. I then take their response and e-mail my regulatory contact at the OCC and get his nod on the response. ( And I keep the documentation!)

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#366960 - 06/02/05 03:47 PM Re: MSB - check cashing
Sound Tactic Offline
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Sound Tactic
Joined: Feb 2005
Posts: 5,349
Consider filing a SAR on the fact that you believe them to be an MSB and they will not register.
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#366961 - 06/02/05 03:56 PM Re: MSB - check cashing
dare2dream Offline
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Joined: May 2005
Posts: 128
California
I was in a seminar last week, and they concurred with Anon (#2) stated. You will have to continue to monitor the account, and if they do continue to do the activity, then you have a choice to make if they are not compling with the law and the risk associated to your institution of them not complying with the law.
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#366962 - 06/02/05 03:58 PM Re: MSB - check cashing
Sound Tactic Offline
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Sound Tactic
Joined: Feb 2005
Posts: 5,349
A local bank in our city (fairly large bank) just dropped all of their MSB customers because only a few were not compliant. Just food for thought.
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#366963 - 06/02/05 04:00 PM Re: MSB - check cashing
dare2dream Offline
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dare2dream
Joined: May 2005
Posts: 128
California
MSB's are a serious issue of work - hands down... They take a good chunk of my time, and with everything continuing to change - I think I get a handle on things, and then WHAMO, nope... back to the drawing board!
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The trouble with real life is that there is no danger music.

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