If one of our customers is registered as an MSB because he uses an account at another bank for check cashing purposes, do we need to follow for license, etc.at our bank? He does not use the account here for check cashing purposes.

IMHO - If they are a known MSB, then the MSB guidance provided by the regulators apply, regardless of whether they appear to be not conducting their MSB activity through your bank.

Thanks,
Getting a copy of their registration is one thing- It is like pulling teeth to get evidence of a program and evidence that they are testing the program!

I appreciate your response.


BSA has turned into a full time job leaving little room to do the regularly scheduled Compliance training and testing!

It shouldn't be that hard to get these things. It should be a either or situation. Either we have it or we close your account - period! Most of these accounts, unless you have adjusted your pricing, are big money losers anyway.

... and frankly, it's surprising that the bank through which the MSB funnels its MSB activity hasn't insisted that it get ALL of the MSB's business -- to make its monitoring job easier.

rlcarey, do you charge your MSBs other than the basic business account charges?

Since I am now a consultant - no I do not charge MSBs a separate charge (Hoever, I am available to perform BSA compliance reviews of MSBs ).

However, I have been in banks that do. The important thing would be to insure that your commercial analysis compensates you correctly for checks deposited and cash withdrawn and in addition to that you charge them a separate service fee adequate enough to the cover the cost of on-going reviews and monitoring. I am of the contention that if a bank has a number of MSB accounts, they can pay for the whole compliance function of the bank (and they say that compliance is a cost center - well it is time to turn the tables on that mentality ). I have seen additional fees as high as $1500 for a large MSB.

Thanks rlcarey! I think I will suggest an additional fee and see what happens!