The Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) is seeking public comment on the Advance Notice of Proposed Rulemaking (ANPR) regarding the impact of Bank Secrecy Act (BSA) regulations on the ability of money services businesses (MSBs) to open and maintain accounts and obtain other banking services at banks and other depository institutions.

Does anyone have any information that can be used for purposes of writing this letter regarding this impact? Any studies? I would like to include factual information outside our own institution's experience.