I see that dealers in precious metals, stones, jewels are considered NBFIs, but wonder if a retail jewelry store or a jewelry wholesaler would also fall into this category.

Here's a prior thread for those who wonder why the "dealer" actually meets the definition of a financial institution and is, accordingly, an NBFI.

devsfan, I agree with you, the jewelry store's label isn't clear. However, I would treat it as I would treat a dealer for the purposes of evaluating it for additional monitoring and documentation. (Given the mechanical, buying and selling, nature of the "dealer" definition, the wholesaler may actually be a dealer for this purpose.)

Before someone adds that the jewelry dealer or store are "high risk" businesses, they aren't. The new examination procedures are more politically correct and regulators don't use that label to stigmatize any particular type of business. (Apparently, they learned their lesson on MSBs.) Any "high risk" label is assigned to the individual customer by the bank itself based solely on the facts of the case. The examination procedures go no further than to list certain persons and entities as deserving of evaluation and to suggest the potential application of risk mitigation measures.

what requirements will the banks have to accept

we are not an NBFI and MSB but spend a lot of time and energy documenting and monitoring them

will the banks be asked to handle this new category the same way??????????