Ruling (FIN-2008-R009) on Whether a Company that Offers a Loan Acceleration Product for Consumer Financing is a Money Services Business
FIN-2008-R009Issued: September 18, 2008Subject: Administrative Ruling on Whether a Company that Offers a Loan Acceleration Product for Consumer Financing is a Money Services Business
Dear [ ]:
I am responding to your letter, dated September 11, 2007, to the Financial Crimes Enforcement Network ("FinCEN"). You have asked us to determine whether [ ] (the "Company") is a money services business, specifically a money transmitter as that term is defined in our regulations.