February 2002
Definition of Check Casher (Payday Lenders)
Dear [ ]:This letter responds to your letter to Judith R. Starr, Chief Counsel of the Financial Crimes Enforcement Network (“FinCEN”) dated December 14, 2001, in which you seek, on behalf of [ ], interpretive guidance regarding application of the Bank Secrecy Act (“BSA”), 31 U.S.C. 5311-5331, and its implementing regulations found at 31 CFR Part 103. Specifically, you ask whether certain subsidiaries of [ ] must register with the Department of the Treasury under 31 CFR 103.41 as check cashers. Ms.