Posted By: CrashDavis
Money Service Businesses - 11/06/14 02:32 PM
I have a question regarding Money Service Businesses.
We have about 5 money service business customers. Most are small convenience stores. In our review of these accounts, we keep a copy of the MSB Registration to show they are current in this area. We do not have a copy of the MSB's BSA Policy. I would guess that they probably do not have one because they are a small business and do not know how to develop one. Are we as the bank required to make them as a BSA Policy or just show documentation that the should have one.
We are getting ready to have an examination from our state regulators and want to know how to answer to them if they ask.
Thanks
We have about 5 money service business customers. Most are small convenience stores. In our review of these accounts, we keep a copy of the MSB Registration to show they are current in this area. We do not have a copy of the MSB's BSA Policy. I would guess that they probably do not have one because they are a small business and do not know how to develop one. Are we as the bank required to make them as a BSA Policy or just show documentation that the should have one.
We are getting ready to have an examination from our state regulators and want to know how to answer to them if they ask.
Thanks