Do any of you actively search the MSB web-site when opening accounts for businesses, to confirm if they are registered as an MSB or rely on them when asked (we specifically ask if they cash checks for their customers and, if so, are they in excess of the $1,000 limit).

Are you asking if anyone checks the MSB site for all new business accounts being opened? If that is your question we do not and I doubt if it would be worthwhile. The proper questions being asked at account opening combined with diligence on the part of tellers accepting deposits (identifying 3rd party checks) and monitoring ACH and wires should enable you to identify those MSBs that did not "fess-up" at account opening.

In addition to the EDD at account opening and a periodic scrubbing of ACH trans to identify MSB's (and also businesses with ATM's) we also annually check our state's electronic lists of licensed MSB's to identify any previously undisclosed MSB customers, and ensure our existing MSB's are still licensed.

If you don't mind me asking, when you review the ACH and ATM transactions, what is it you're looking for to identiy a potential MSB?

We look for western union in large amounts, Moneygram, and the like. any large amounts that aren't explained by the customer's business purpose, google will usually tell you what the ACH company does. For example- if you have a grocery store that states they are not an MSB (we have a form we give businesses listing the types of activities that would constitute an MSB and then asks them if they engage in any of the activity)- and then you see large amounts coming out daily from some sort of funds transfer company, you could have an MSB issue...

http://www.fincen.gov/financial_institutions/msb/definitions/msb.html

Thanks. We have a Customer Due Diligence (CDD) worksheet for businesses that asks all the pertinent questions to identify an MSB, but the monitoring would help. We just implemented BAM from Bankers Toolbox, so I'll review their capability to do the search on an automated basis. Thanks again.

Doug, if you determine that BAM has that capability, and would like more info on our scrub (which is done thru Patriot Officer), PM me with your contact info.