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#901644 - 02/07/08 07:54 PM Check cashing forgiveness
chatty Offline
Junior Member
Joined: Feb 2006
Posts: 34
How many times can a convenience store repent for cashing checks over $1000 without registering as an MSB? We've let a customer sign an affidavit that it was a mistake and he wouldn't do it anymore but now we see where he's deposited several more since then. I know he knows he can't do that, probably was just hoping not to get caught. How do other banks handle? Tell him to register or close his accounts?

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#901646 - 02/07/08 07:55 PM Re: Check cashing forgiveness chatty
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
Zero times - once you cross the threshold you are an MSB.
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#901682 - 02/07/08 08:17 PM Re: Check cashing forgiveness rlcarey
chatty Offline
Junior Member
Joined: Feb 2006
Posts: 34
I sure thought something came out several years ago where they could repent and say they wouldn't do it anymore but now I can't locate the ruling.

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#901729 - 02/07/08 08:50 PM Re: Check cashing forgiveness chatty
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
You are probably thinking about this one:

http://www.fincen.gov/fincen_ruling2005-3.pdf

However, this deals with a registered MSB ceasing MSB activities - not an unregistered MSB saying they won't do it again.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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