I'm in the process of updating our MSB procedures. In light of the Final Rule on Prepaid Access, I want to go ahead and update the definitions section in our procedure. I've read the Final Rule (and re-read and re-read) and I haven't come to a conclusion on the limits.
For the definition of an MSB, we are all use to the "more than $1,000 per person per day" lingo (with the exception of money transmitters). Now, with "providers and sellers of prepaid access", does the $1,000 per person per day threshold apply? I've read so many exclusions (i.e. closed loop not to exceed $2,000....) that I'm left confused.
I need to uderstand the definition as we require MSBs to be approved by executive mgmt prior to opening an account. I would appreciate comments from anyone who has a clearer understanding than me.