Regulatory Alerts2009-02-20
Added
Ruling on Whether a Company Engaging in Microfinance is a Money Services Business
A company acting as a clearinghouse for micro-loans between lenders and borrowers is not considered a money transmitter under 31 C.F.R. § 103.11(uu). This determination applies because the acceptance and transmission of funds are an integral part of the loan clearinghouse services rather than a separate and discrete service. Consequently, the company is not required to register as a money services business with FinCEN under these specific operational conditions.