June 2005

Dear [ ]:
This letter responds to your request for an administrative ruling, dated April 21, 2005, with respect to whether [the business] is a money services business for purposes of regulations implementing the Bank Secrecy Act found at 31 CFR Part 103, and if so, which regulations apply to [the business]. Based solely on the representations made in your April 21, 2005 letter, the Financial Crimes Enforcement Network (FinCEN) concludes that [the business] is not a money services business, and is therefore not subject to the Bank Secrecy Act or its implementing regulations.

Dear [ ]:
This responds to your letters to the Financial Crimes Enforcement Network (“FinCEN”) of March 18, 2005, and June 14, 2005, requesting a determination as to whether (“bank”) must continue to treat its customer (“business”), which is currently registered as a money services business (check casher) with FinCEN, as a money services business although it no longer engages in check cashing activity that meets the definitional threshold of a money services business under Bank Secrecy Act regulations (31 CFR 103.11(uu)(2)).