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#1786016 - 02/14/13 03:21 PM MSB check casher question
notime4dat Offline
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Joined: Nov 2012
Posts: 14
FinCEN guidance from 2006 states that if a business is cashing payroll checks for employees exceeding $1,000.00 per person per day in one or more transactions, the business does not meet the definition of an MSB. Is this still true? Also, if the business cashes checks for an owner of the business, or for anyone, but it is not necessarily a payroll check, then does it meet the definition of an MSB?

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#1786174 - 02/14/13 05:25 PM Re: MSB check casher question notime4dat
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
You are correct that a business cashing payroll checks for their employees would not be considered an MSB. Also, I would consider any check issued by the business payable to an employee (expense reimbursement, etc) could also be cashed, but any other check that is brought in by the employee and cashed would trigger the MSB if the $1,000 threshold is met.

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#1786375 - 02/14/13 08:56 PM Re: MSB check casher question notime4dat
leo_bsayer Offline
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Joined: Aug 2006
Posts: 645
If the business cashes its own checks, payroll or otherwise, does the same apply? Or, must it be payroll checks only and/or payable to an employee for something such as expense reimbursement.

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#1786476 - 02/15/13 02:45 AM Re: MSB check casher question notime4dat
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
It would see the cashing of any check issued by the business similar to this ruling:

http://www.fincen.gov/statutes_regs/guidance/html/FIN-2007-R001.html
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