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#1627003 - 11/10/11 02:24 PM Prepaid access MSBs
liventhedream Offline
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Joined: Mar 2006
Posts: 166
Is anyone doing anything with their existing customer base to address the new definition of an MSB, which includes providers and sellers of prepaid access?

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#1627017 - 11/10/11 02:35 PM Re: Prepaid access MSBs liventhedream
J2C Offline
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#1629100 - 11/16/11 04:25 PM Re: Prepaid access MSBs J2C
*W*W* Offline
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Posts: 835
Does anyone have a link to the MSB definition changes or any reference materials? I listened to the FinCEN training online and didnt get anything out of it.
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#1629116 - 11/16/11 04:34 PM Re: Prepaid access MSBs *W*W*
ACBbank Offline
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Link to the press release for the Prepaid Access Guidance and the Q & A:

http://www.fincen.gov/news_room/nr/pdf/20110726b.pdf

http://www.fincen.gov/news_room/nr/pdf/20111102.pdf

Link to the press release for the MSB Guidance:
http://www.fincen.gov/news_room/nr/pdf/20110715.pdf
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#1629502 - 11/17/11 01:39 PM Re: Prepaid access MSBs ACBbank
Dolly Nugent Offline
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Southern California
Is anyone going to be soliciting existing customers to determine if they sell prepaid access cards?
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#1635683 - 12/06/11 02:22 PM Re: Prepaid access MSBs Dolly Nugent
liventhedream Offline
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Joined: Mar 2006
Posts: 166
I am going to just look at my MSBs. I have been having a hard time figuring out what to do and I don ot think the examiners know what they expect yet either.

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#1635777 - 12/06/11 04:03 PM Re: Prepaid access MSBs liventhedream
Retread Offline
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See: http://www.perkinscoie.com/news/pubs_detail.aspx?op=updates&publication=3419

For what it's worth, it's always interesting when a law firm analyzes the rules and gives an opinion.
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#1635951 - 12/06/11 07:01 PM Re: Prepaid access MSBs Retread
*W*W* Offline
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Joined: Feb 2010
Posts: 835
The release from FinCEN-July 26, 2011 gives examples of prepaid devices; "plastic cards, mobile phones, electronic serial numbers, key fobs..." What are electronic serial numbers and key fobs?
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#1635988 - 12/06/11 07:12 PM Re: Prepaid access MSBs *W*W*
dickr Offline
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Joined: Feb 2010
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Middlesex Cty NJ
Has anyone found (if there is one)a comprehensive list of Prepaid service providers. I was thinking that a search of ACH files might give me some leads, but I'm not sure what names to look for or how to identify them. Thanks
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#1639904 - 12/15/11 11:05 PM Re: Prepaid access MSBs liventhedream
husker14 Offline
Member
Joined: Aug 2005
Posts: 50
we just had a FDIC BSA exam and they addressed this but honestly they were not sure what to look for. They just asked us to try and identify these at account opening and develop procedures. When we asked clarification type questions all we got was a copy of the guidance and the Q&A.

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