The new guidance settles the age old questions about a firm cashing its employees' or vendors' checks and about tax preparers cashing checks (not MSBs if that is all they do).

What will we agonize over now?

Does the same logic apply to finance companies who make a loan and then cash the loan proceeds check for the customer? One of our customers called the Treasury department last year to ask that questions and was told that they ARE a MSB. Is that now reversed?

Based on scenario #3, I think if your customer called today they would get a different answer. You might want to call FinCEN and ask.

I agree. The basis for the answers in the FAQ is that the proceeds could have just as easily been distributed in cash as a check, unlike a true check casher who cashes checks given by a 3rd party.