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#1693319 - 04/27/12 02:32 PM MSB - do you bank 'em?
Lisa_Bates Offline
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Lisa_Bates
Joined: Dec 2007
Posts: 5,762
Does your FI allow Money Service Businesses to open accounts? If so, would you be willing to share your best practices??

If so, please message me...I've got questions smile

Thanks!!!

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BSA/AML/CIP/OFAC Forum
#1694531 - 05/01/12 08:23 PM Re: MSB - do you bank 'em? Lisa_Bates
Lisa_Bates Offline
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Lisa_Bates
Joined: Dec 2007
Posts: 5,762
**bump**

Still have MSB questions smile

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#1694535 - 05/01/12 08:27 PM Re: MSB - do you bank 'em? Lisa_Bates
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Why the secrecy? If you have questions, just ask.
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#1694536 - 05/01/12 08:30 PM Re: MSB - do you bank 'em? Lisa_Bates
BrianC Offline
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BrianC
Joined: Nov 2004
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Illinois
And if you're concerned that providing too many specifics will identify specific clients, follow the directions to register for Private Forums
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#1694542 - 05/01/12 08:39 PM Re: MSB - do you bank 'em? Lisa_Bates
Lisa_Bates Offline
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Lisa_Bates
Joined: Dec 2007
Posts: 5,762
I am wondering what types of enhanced due diligence others banks do for MSB customers....do you site visit? Do you require special agreements or assurity bonds for check cashing businesses? Do you have a special monthly service charge?

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#1694547 - 05/01/12 08:50 PM Re: MSB - do you bank 'em? Lisa_Bates
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
We don't bank them any more, but a site visit was always required for obvious reasons. There are differences between MSB's, so I don't think there is one standard approach. For example, a busy Western Union location is not the same as the mom & pop convenience store which just also happens to cash a few checks a week.

The basics are: 1. request proof of registration with FinCEN and the state (if applicable). 2. Request copies of their AML policies & procedures. 3. Talk to their "Compliance Officer" to get an idea if they really understand what's going on.

In my area, the banks that do bank MSB's kill them on fees. I'm not talking analysis either. This is a specific fee based solely on the customer being an MSB. Depending on all of the relevant factors, I have heard of fees ranging from $500-$3,000 per month.
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