I currently have an audit reconsideration case that’s been on hold for eighteen months. I guess I have nothing to complain about, though. One unlucky attorney waited over six years to get an answer from the Financial Crimes Enforcement Network (FINCEN).
On October 22, 2007, an attorney asked, “…[W]hether a payment mechanism based on payable-through drafts that the Company offers to its commercial customers (the “customers”) makes the Company a money transmitter under the regulations.” On November 13, 2013, FINCEN said yes.
There is a bit more to this case than what’s noted above. FINCEN issued regulations in July 2011 that impacts the specific facts and circumstances of the matter. And I’m not really that concerned with this issue (it has no direct impact on my clients).
What does bother me is that there’s no obvious reason why it took FINCEN six years to respond. Of course, my client waiting for his audit reconsideration is hoping that it won’t be another 54 months for his case to be reviewed.