Our institution has made the decision not to open accounts for MSB's. Are we required, or allowed, to display a reference to this fact at our new accounts desks? Is anyone doing anything similar to this?

Thanks

We have made it policy not to bank MSBs also, but we do not have a notice/sign or anything. Our CSRs are supposed to ask pertinent questions to find out if a new customer is a MSB and if they are, inform them of our policy of not opening accounts for MSBs.

We haven't had an instance of someone wanting to open an account and they were a MSB and we turned them away, so this procedure works in theory right now, but if it actually happened, I don't know what would happen.

You're neither required to nor prohibited from posting a sign that says what type of accounts you will not open.

Laura L's suggestion follows the current regulatory thinking, ask some due diligence questions at account inception regarding whether the new business customer intends to cash checks, do currency exchanges, etc. If they say "Yes," banks willing to open the account would move to a higher tier of enhanced due diligence and obtain enough information to perform a risk assessment.

Banks unwilling to open the account can simply pull the plug on the account opening process.

Thanks LauraL and Ken.