Opinions from the Washington Division of Division of Consumer Services clarifying RCWs and WACs related to Washington Money Services Providers.
DFI Director's Interpretive Statements
See Also: Interpretive Statements from the Director of DFI
Note About The Payment Processing Interpretive Statement
The Department has revised the December 7, 2015, Interpretative Statement regarding payment processing under the Act. The revisions:
- Clarify that money transmission can occur by a constructive control of the flow of funds versus an actual control of funds. An example is a business model that directs the flow of funds from and to bank accounts versus a business model that includes the payment processor taking funds into its own bank account or an FBO account it controls.
- Clarify how the Department’s decision to issue a license waiver is consistent generally with FinCEN’s analysis that payment processing may be a lower risk to consumers.
- Clarify implementation of the Interpretive Statement.
For those of you who have received the License Waiver, no changes are necessary based on the revisions. Thank you for helping us get these waivers out efficiently.