Skip to content
BOL Conferences
Thread Options
#1165370 - 04/17/09 02:33 PM Party Store/Checks for Cash: MSB?
ComplianceGurl, CRCM Offline
Platinum Poster
Joined: Jul 2007
Posts: 500
We have a business account that is a convenience/party store. They cash 3rd party checks, under $1000. They also offer a service where they basically extend loans. They have some kind of an agreement with Cash for Checks, LLC, where they cash personal checks, hold the checks until a certain date or when the customer comes back in with a "good" check. The party store receives a quarterly commission from the Cash for Checks business. Does this make them an MSB regardless of the amounts of the checks?
Thank you for any light you can shed on this!!

Return to Top
BSA/AML/CIP/OFAC Forum
#1165418 - 04/17/09 02:56 PM Re: Party Store/Checks for Cash: MSB? ComplianceGurl, CRCM
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
Not unless they cross the $1,000 threshold.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1165434 - 04/17/09 03:06 PM Re: Party Store/Checks for Cash: MSB? rlcarey
ComplianceGurl, CRCM Offline
Platinum Poster
Joined: Jul 2007
Posts: 500
So it would be the amount of the check plus any fees correct? Should I get a copy of their agreement? Thanks Randy!

Return to Top
#1165584 - 04/17/09 04:33 PM Re: Party Store/Checks for Cash: MSB? ComplianceGurl, CRCM
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
It is all based on the amount of cash that is actually exchanged. Copies of agreements are always a consideration in the due diligence process.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z