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Can an Individual Be Considered an MSB?

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Question: 
Can an individual be considered an MSB? For example: we have a customer who cashes checks for his friends, some in amounts greater than $1,000.00, but this person does not operate a business.
Answer: 

Yes, an individual that cashes checks for persons for greater than $1,000 in a single day is an MSB and would have to register as such. There is no requirement that an MSB be a entity.

For example, see the instructions for Box 9 on the MSB Registration FinCEN Form 107:


Item 9--EIN (entity), SSN/ITIN (individual). If the registrant is an entity enter its employer identification number (EIN). If the registrant is an individual and a U. S. Citizen or an alien with a social security number, enter his/her SSN. If the registrant is an individual who is an alien and has an individual taxpayer identification number, enter his/her ITIN. If a number has been applied for, but not yet received, leave item 9 blank. When the number is received file a corrected form.



First published on BankersOnline.com 2/04/08

First published on 02/04/2008

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