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#1238454 - 08/25/09 02:44 PM "Redeemer" definition
compliancemom Offline
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Joined: Mar 2009
Posts: 22
West TN
ABA's summary of FinCen's proposed changes to the MSB definition indicate: (redeeming does not include payment for goods or services – footnote 60 p. 22135")

This language is found in a 1999 FR, but does "redeem" currently not include payment for goods or services? If so, does this mean that a furniture store who would accept $1100 in gift cards or money orders for purchase of a new couch not qualify as an MSB?

Maybe I'm just confused....
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#1239522 - 08/26/09 04:26 PM Re: "Redeemer" definition compliancemom
Auditor247 Offline
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Auditor247
Joined: Jun 2006
Posts: 140
Redeemers are really like the check cashers whereas if the customer does not receive over $1000 back in cash or monetary instruments after payment of the obligation, then they are not considered a Money Services Business relative to that activity.


FIN-2007-R002 - Whether a Business that Cashes Checks Payable to Customers to Apply Proceeds to the Repayment of Customers’ Obligations is a Money Services Business

http://www.fincen.gov/statutes_regs/guidance/pdf/FIN-2007-R002.pdf

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