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#2147550 - 09/26/17 02:12 PM MSB-confiming if registration is required
Sunshine Banker Offline
Member
Joined: Jun 2012
Posts: 80
Florida
Received verification (letter) from ABC, Corp. that the store" has been an authorized money transmitting agent since xxxx."
No check cashing over $1,000, atm serviced by outside vendor, no stored value card, no travelers checks, sells MO through Western Union. Reviewed the exam manual and found-pg 301 at bottom- Refer to 31 CFR 1022.80. With the information provided, I believe registration with FinCEN is not required. Did I miss something? The store was previously registered as an MSB, that expired, it prompted why the change-only change is they no longer a have relationship with a previous money transmitter? We currently have a loan relationship, depository acct for loan payment-no other activity on Depository acct.

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#2147555 - 09/26/17 02:22 PM Re: MSB-confiming if registration is required Sunshine Banker
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,361
Galveston, TX
If they are a WU agent, then they are an MSB - just not one that has to register.
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#2147559 - 09/26/17 02:33 PM Re: MSB-confiming if registration is required rlcarey
Sunshine Banker Offline
Member
Joined: Jun 2012
Posts: 80
Florida
Received copy of WU North America Agency Agreeemnt- Verbiage -Agent and WUNA agree as follows;....Yes they are an agent. Thank so much.

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#2147749 - 09/27/17 02:04 PM Re: MSB-confiming if registration is required Sunshine Banker
Cape Codder Offline
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Joined: Jul 2011
Posts: 413
Sunshine, in MA, the parent MSB (i.e., Western Union) is required to separately register each location that is a funds transmittal agent for them. You might want to check your state requirements.
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