Regulatory Alerts2009-02-20
Added
FinCEN Ruling FIN-2008-R010 on Money Services Business Status for Social Security and Veteran Benefits Agents
A company acting as an authorized agent for the collection and disbursement of Social Security and Veteran Administration benefits, as well as consumer loan proceeds, is not required to register as a money services business. The ruling determines that issuing money orders to discharge pre-existing obligations does not constitute selling money orders, and exchanging those specific money orders for cash constitutes rescission rather than redemption. Additionally, the company's role in processing ACH deposits and disbursing funds to intended recipients qualifies it as a payment processor, excluding it from the definition of a money transmitter.