It can apply only if the firm maintains customer information concerning fewer than 5,000 consumers, and it removes only four listed duties. Citation: 16 CFR 314.6.
Primary source: 16 CFR 314.2(h)(2)(vi)-(vii)
Does the under-5,000-consumer exemption apply to a check casher, wire transferor, or money transmitter?
Details
Transaction volume can push even small storefronts above 5,000 consumers. If the firm is below the threshold, 16 CFR 314.6 still does not remove security-program duties. The firm should document the count method, because old files, leads, former customers, and retained records can matter.
Primary source: 16 CFR 314.2(h)(2)(vi)-(vii).
Related obligations - not covered by this packet: money services businesses may have BSA/AML registration, reporting, agent-list, and AML-program duties. Policywright's WISP packet does not satisfy BSA/AML program requirements.
FAQ
Does the under-5,000-consumer exemption apply to a check casher, wire transferor, or money transmitter?
It can apply only if the firm maintains customer information concerning fewer than 5,000 consumers, and it removes only four listed duties. Citation: 16 CFR 314.6.
What is the data-flow issue for a check casher, wire transferor, or money transmitter?
Customer information lives in teller systems, ID scans, transaction logs, OFAC or fraud-screening tools, agent portals, receipts, SAR-supporting notes, and money-transmission platforms. The WISP should map agent locations and hosted provider access separately from headquarters systems.
Is this legal advice?
No. It is source-cited educational content for a template product, not legal advice.