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#2122206 - 03/16/17 01:53 PM Employer Helping Employee Cash Check
ComplianceGurl, CRCM Offline
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Joined: Jul 2007
Posts: 498
We have non-customers attempting to cash on-us payroll checks. Many of the individuals cannot present proper ID to be able to cash these checks. They are endorsing the check back to the employer and the employer is coming in to cash the check for them. Would this make the employer a "check casher" for MSB purposes even though it's the bank actually cashing the check?
Thank you!

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#2122214 - 03/16/17 02:07 PM Re: Employer Helping Employee Cash Check ComplianceGurl, CRCM
Sunshine Lady Offline
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Sunshine Lady
Joined: Apr 2014
Posts: 629
No, I recently called FinCEN about that and no they are not required to register as an MSB if they are cashing their own payroll checks even if they are over $1.000.00.
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Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney

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#2122228 - 03/16/17 02:39 PM Re: Employer Helping Employee Cash Check ComplianceGurl, CRCM
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
FIN 2006 - G005

While a one off transaction might not be a concern, employers who say they are "cashing" their employees' checks may be padding their payrolls, engaging in human trafficking, etc. Concern over MSB status may be minor in comparison.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#2122270 - 03/16/17 05:18 PM Re: Employer Helping Employee Cash Check ComplianceGurl, CRCM
ComplianceGurl, CRCM Offline
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Joined: Jul 2007
Posts: 498
Thank you both for your feedback!

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