Q&A
We are originating a HELOC loan to fully pay off an existing HELOC loan. Since there is no new money involved, would Right of Rescission apply?
Answer: Since the property is being deeded over to the borrower, the borrower is essentially purchasing the property for what is remaining Yes. Although no new money is being advanced, this is a new HELOC that will allow a customer to redraw on funds from the line once the loan is paid down. The Right
If the financial institution has a customer with a virtual currency kiosk located on their premises, (i.e. inside the gas station or convenience store), do we need to treat them as a Money Service Business (MSB)?
Answer: It depends. If your customer is simply leasing out the space to the virtual currency kiosk owner/operator and collecting “rent” payments, the owner of the kiosk is the MSB, not your customer. The owners of the kiosk are required to register with FinCEN as an MSB. Your due diligence on your customer would be
