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#520387 - 03/22/06 07:07 PM MSB
CrashDavis Offline
Gold Star
Joined: Jun 2005
Posts: 283
I reviewed an account today to determine if they are a MSB. I found two checks in the past three months of statements where they had a check deposited to the business account. The check was payable to cash and was on the owner's personal account. Would you consider this a MSB. There were no other customer's he was cashing checks for over $1,000.00

Thanks in advance for your help.

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#520388 - 03/22/06 07:44 PM Re: MSB
SBR2448 Offline
Member
SBR2448
Joined: Sep 2005
Posts: 88
I'm slightly confused as to the situation you are describing, but I'll take a stab at this. If I am understanding the situation, in the past three months only 2 checks over $1,000 have been deposited to this account and both were from the owner's personal account. It sounds to me like the owner is transfering money to the business account, possibly to cover more expenses than the business itself can cover. Hope this helps.

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#520389 - 03/22/06 07:47 PM Re: MSB
lawmansbabe Offline
Gold Star
Joined: Mar 2006
Posts: 285
Oklahoma
could it be that they "cashed" the check at the business?

(you know, like took cash out of the petty cash or something, and replaced it with a personal check)
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#520390 - 03/22/06 08:30 PM Re: MSB
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
I would not consider this as "MSB activity". Hopefully, an examiner would agree.

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#520391 - 03/23/06 03:51 PM Re: MSB
SLU Voice Offline
Gold Star
SLU Voice
Joined: Apr 2004
Posts: 288
Hammond, LA
I also would not consider this MSB activity, and I believe that was addressed in some of the follow-up guidance that was issued last year.

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#520392 - 03/23/06 05:18 PM Re: MSB
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
I would ask the customer to explain the nature of these transactions--did he cash his own personal checks or make a little personal capital injection into the business. If he cashed the checks, it is time to have the "MSB" discussion; if not, case closed.
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#520393 - 03/23/06 06:22 PM Re: MSB
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
I would not even ask the customer about it.
It is a non event I think.

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