Comment on FR Doc # 2010-17505

We would like FinCEN to take in consideration that there are number of US MSBs that services foreign customers who require higher initial, daily and withdrawal limits than proposed by FinCen $1k limit. These customers receive payroll, commission and loyalties checks and electronic payments greater than $1k per transaction. We would like to request FinCen to exempt MSBs from the above limits who service foreign customers who require higher card limits. Newly proposed by FinCEN limits will negatively affect many US MSBs businesses and turn number of foreign customers away from using MSBs services. Background information on MTACC and other similar MSBs businesses: MTACC is Check Cashing and Money Transmitting company. Currently we are using foreign-based bank to load our customers prepaid card when our customers funds have been processed. We service number of none US customers who receive payroll, commission, loyalties payments both via checks or electronic payment.Our customers find our services very comparatively priced and fast compared to similar services offered in their natives countries. Often the payment amounts we process for our foreign customers are greater than $1k per transaction.The average amount of our customers transaction is $5k.However,we have dozen customers who receive payment greater than $10k.We would like to request FinCen to exempt MSBs that service foreign customers who require higher card amounts limits. Because,having $1k daily withdrawal limit will increase MSB cost dramatically. For example if MSB needs to load our customer card with $5k funds MSB will have to brake a transaction in 5 different transactions which will cost to us $10.00 ($2.00 per transaction). Thus, MSB cost to load to a single customer card will increase by 500%. We strongly feel that MSBs who act as an intermediary processor of checks and electronic payments for foreign customers should be exempted from proposed FinCen prepaid card limits.