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#716840 - 04/16/07 05:08 PM Non-Bank Financial Institutions?
hawkfan Offline
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What is considered a non-bank financial institution? I seem to re-call a list somewhere, but can't find it. I know MSB's are considered NBFI's, but what else is? If there is a list, can you also point me to a link or website. Thanks.

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#716859 - 04/16/07 05:45 PM Re: Non-Bank Financial Institutions? hawkfan
MagicCity Offline

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#716884 - 04/16/07 06:24 PM Re: Non-Bank Financial Institutions? MagicCity
Retread Offline
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From IRS Manual - December 2006

4.26.3.2.1 (12-12-2006)
Identification of BSA Entities
The BSA coordinator will identify for examination those entities for which IRS has BSA jurisdiction. Most entities under IRS jurisdiction are commonly referred to as nonbank financial institutions (NBFIs). IRS also has delegated authority to examine banks and other financial institutions that are not examined by federal bank supervisory agencies for safety and soundness. Thresholds determine if some financial institutions are subject to the BSA. ( See IRM 4.26.5.) NBFIs currently include:

Money Services Businesses (MSB), subject to certain transaction thresholds

Casino and Card Clubs (including Indian tribal casinos)

Insurance companies subject to the AML compliance program requirements of the BSA

Dealers in precious metals, jewels and gems subject to the AML compliance program requirements of the BSA.
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#717272 - 04/17/07 02:49 PM Re: Non-Bank Financial Institutions? hawkfan
Elwood P. Dowd Offline
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Certainly, the entities listed in Retread's post are NBFI's. Technically, the all inclusive list would be to take BSA's definition of "financial institution" and subtract from that everything listed in BSA's definition of "bank." The remainder would be non bank financial institutions.

For the sake of deciding who you should evaluate as a customer subject to expanded examination overview I suggest you use a simpler approach and include every customer providing financial services including, but not limited to, selling checks, cashing checks, selling stored value cards, sending money transmissions, etc.
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