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MSB Licensing & Registration
easy
A fintech startup builds an app that lets users send dollars to each other and cash out to their bank. Why does this typically make the company a money services business (MSB) under FinCEN's rules?
A
It holds a banking charter, which automatically triggers MSB status
B
It accepts value from one person and transmits it to another, meeting the definition of a money transmitter
C
It earns revenue from interchange fees, which FinCEN classifies as transmission
D
It stores customer funds for more than 24 hours, which is the regulatory trigger
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