Regulatory Alerts2009-01-12
Added
Ruling on Whether a Company Offering a Loan Acceleration Product is a Money Services Business
A company that electronically debits consumer accounts to transmit funds to a creditor for accelerating vehicle loan payments is classified as a money transmitter under FinCEN regulations. This classification applies because the acceptance and transmission of funds is not an integral part of executing or settling a transaction other than the funds transmission itself. Consequently, the company is required to register with FinCEN, implement anti-money laundering programs, and report suspicious activities and currency transactions.