MSBA Comment Letter on ID No DFS-50-150004-P Regulating Transaction Monitoring

January 26, 2016

New York Department of Financial Services

One State Street

New York, NY 10004

Attn: Shirin Emami, Acting Superintendent

Mr. Gene Brooks

Re: I.D. No. DFS-50-1500004-P, Regulating Transaction Monitoring and Filtering Systems Maintained by Banks, Check Cashers and Money Transmitters

Dear Superintendent Emami and Mr. Brooks:

I am writing on behalf of the Money Services Business Association (the “MSBA”), a new trade association focused on the non-bank money services industry, including licensed money transmitters and their agents and/or authorized delegates, payment card issuers and distributors, payment processors, international remittance companies, bill payment companies, mobile payment application providers, payment aggregators, virtual currency exchanges and administrators, eWallet providers and other similar money services providers that are engaged in payments.