During the last AuditLink focus group, we mentioned that we had found two Money Stores through our daily monitoring. In both instances, we noticed the accounts had large outside check deposits followed by large cash withdrawals on either the same or next day. In order for an MSB to be a legitimate business, there are several requirements from both the Federal and State Governments. Our friends at Fox Community Credit Union were nice enough to provide us with a list of five items that their auditors are looking for from MSBs. Those items are:
- FinCEN Registration – and renewals
- State registration
- BSA/AML Policy is in place and annually updated
- BSA training is held annually
- BSA/AML independent audit is completed annual
There may be additional licenses or other special requirements for each state. We also learned that MSBs are paying more attention to Credit Unions because Banks are increasing the number of requirements and even requiring bonds to cover the possibly of bad checks. Even with the attention turned to Credit Unions, we were told that only 3% of the CUs at a recent CUNA conference were accepting MSBs.
If you believe that you may have an MSB account at your Credit Union, feel free to contact AuditLink. We could review the activity and provide you with a recommendation for the account.
For more information on MSBs, visit the FINCEN website.