June 16, 2006
FinCen's Advance Notice of Rulemaking
Attached please find FinCEN Advance Notice of Proposed Rulemaking (ANPR) (PDF) related to money service businesses (MSBs). FinCEN is seeking input from MSBs regarding the impact of the Bank Secrecy Act on their ability to, among other things, open and maintain accounts at financial institutions. Section II. Issues for Comment of the ANPR asks for your input on seven questions related to banking relationships.
Several California MSB licensees have expressed frustration regarding their inability to maintain bank accounts solely because of the nature of their business. We provide this notice as a means and encouragement for you to communicate your concerns and experiences directly to FinCEN. Comments are due to FinCEN no later than July 10, 2006 . We would also appreciate a copy of your submission.
Please feel free to contact Robert Venchiarutti at (415) 263-8511 or by email at firstname.lastname@example.org with any questions.