Regulatory Alerts2004-11-24
Added
FinCEN Ruling 2004-4 – Definition of Money Services Business (Debt Management Company)
FinCEN determined that a debt management company is not a money services business under 31 C.F.R. § 103.11(uu). The ruling concludes that the entity's acceptance and transmission of funds from debtors to creditors are ancillary to the primary service of managing debts, rather than constituting money transmission. Consequently, the business is exempt from MSB reporting, record-keeping, anti-money laundering program requirements, and FinCEN registration obligations.