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#2240804 - 08/07/20 06:27 PM MSB - less than $1000
Lele Offline
Platinum Poster
Lele
Joined: Feb 2007
Posts: 817
In the Sun
I am looking for guidance on opening an account for a Check Casher - Convenience Store that does not cash more than $1,000 for any person on any day in one or more transactions. I think there is still a risk there so want to offer what is expected before we open. Like asking what system do they have in place to ensure that they are not cashing a check for over $1,000. What else do you require/request for this type of account? We bank 2 MSBs and they are a lot of work and have decided to not bring on any additional ones.
Thank you.
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#2240809 - 08/07/20 06:56 PM Re: MSB - less than $1000 [Re: Lele]
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 74,768
Galveston, TX
Most banks treated these just like other MSBs except for requiring that they register, including periodic monitoring to make sure they are not exceeding the $1,000 limitation.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2241653 - 08/27/20 01:49 PM Re: MSB - less than $1000 [Re: Lele]
Jenny Roberts Offline
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Joined: Feb 2014
Posts: 126
Tennessee
I am from TN and we are looking at starting to bank MSB's. In research, I am seeing where MSB's have to be licensed in TN as money transmitters as well. I am being questioned by Senior Mgmt as to if they are registered with FinCEN, then why do they have to be registered with TN. They feel this is the same thing. Do you have any comments I could give them?

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#2241659 - 08/27/20 02:07 PM Re: MSB - less than $1000 [Re: Lele]
IronP2717 Offline
Member
Joined: Feb 2018
Posts: 98
B/C it's the law. I don't know TN state requirements, but their state law is still applicable in addition to federal law. From a BSA risk stand point do you want to bank someone that doesn't adhere to state and federal law applicable to their business?

I'm in Texas. There are add'l state requirements for currency exchange MSBs in addition to FinCEN requirements. That's the reality. PM if you need any MSB tools. I developed the MSB program at a previous bank.

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#2241664 - 08/27/20 02:25 PM Re: MSB - less than $1000 [Re: Lele]
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 74,768
Galveston, TX
If your board of directors and senior management have not a clue as to the requirements and risks involved in banking MSBs in your State, why is this even being considered?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2241667 - 08/27/20 02:42 PM Re: MSB - less than $1000 [Re: rlcarey]
Jenny Roberts Offline
100 Club
Joined: Feb 2014
Posts: 126
Tennessee
I agree completely!

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#2241722 - 08/28/20 12:18 AM Re: MSB - less than $1000 [Re: Lele]
cried Offline
New Poster
Joined: Sep 2015
Posts: 11
We have about 110 MSB's and a very good program to manage them. Additionally, I agree with rlcarey since they are a check casher, you would want them on your EDD review schedule to ensure they aren't exceeding the thresholds for an MSB.

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