Money Transmitters

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During our road trip on highway 66 we stopped at a local shop and I spotted in a dark corner this old map with pins and currencies left by visitors from all over the planet.
Christine Roy, Unsplash

As a corporation that handles ACH transactions on behalf of others, you may have heard your financial institution refer to you as a “Third-Party Sender.” Common examples of Third-Party Senders include payroll processing companies, rent payment companies, and other bill pay providers. If an entity is designated as a Third-Party Sender, it is subject to certain duties under the Nacha Operating Rules (“ACH Rules”), such as the requirements to have an annual ACH Audit conducted and to enter into specific agreements with its clients (the “Originators”).
Continue Reading Third-Party Senders: Are you a Money Transmitter?

A recent trend that we are encountering frequently is software and internet-based platform providers (“providers”) venturing into the world of payments—sometimes unwittingly. A typical scenario looks something like this: A provider develops a platform that assists merchants (such as hair salons, utility providers, or medical offices) accept electronic payments from the merchant’s customers. Most commonly, the providers’ software or technology offerings assist these merchant businesses with virtually every aspect of their operations. So it seems only natural for the providers to offer a payment solution through the platform.
Continue Reading Technology Platform Providers and the Risk of Money Transmission