MSBA Issues a Comment Letter

This comment letter is submitted by The Money Services Business Association (“MSBA”) in response to the Advanced Notice of Proposed Rulemaking, “Beneficial Ownership Information Reporting Requirements,” published by the Financial Crimes Enforcement Network (“FinCEN”) in the Federal Register on April 5, 2021 (the “ANPRM”).1 The ANPRM seeking information regarding the implementation of the Corporate Transparency Act (the “CTA”), enacted into law as part of the National Defense Authorization Act for Fiscal Year 2021. We welcome this opportunity to submit our comments.

The MSBA is a trade association focused on the non-bank money services industry. The MSBA was launched October 2015 by leading industry companies to support the non-bank financial services industry, legislation and regulation tracking, increasing awareness and understanding about the beneficial and secure services provided by the industry and to encourage and promote payments innovation. The MSBA currently has 80 members, which include providers of all products of “money services businesses” as defined by FinCEN regulations other than the United States Postal Service. MSBA’s members thus include money transmitters, dealers in foreign exchange, check cashers, issuers or sellers of traveler’s checks or money orders, providers of prepaid access, and sellers of prepaid access.

The following provides the MSBA’s comments to certain of the specific Questions for Comments set forth in the ANPRM. We first quote the question that we are responding to, followed by our response. We have retained the numbering of each question as was provided in the ANPRM.