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UPDATE June 8:
The House of Representative approved the Financial CHOICE Act, with a vote largely on party lines of 233 to 186.  While the Senate Banking Committee is and has been considering financial reform proposals, it is unlikely that the Financial CHOICE Act as passed by the House will progress in the Senate.

UPDATE June 7:
As expected, House Rules Committee approved a rule on June 6 allowing 90 minutes of general debate that will permit the Republicans to offer 6 amends. Floor consideration expected to start this afternoon or first thing tomorrow morning.

The House Rules Committee has scheduled a meeting on the CHOICE Act for 5:00 PM Tuesday, June 6, to consider the amendments that have been submitted as well as a rule for floor consideration. It is expected that the Committee will issue a rule to bring the bill to the House floor on Wednesday, and that rule is likely to provide for debate and floor consideration of amendments.

There is some speculation that Democratic members may withdraw their amendments in a show of opposition to the bill, similar to their decision last Congress not to participate in the Committee mark-up.  We understand that the Majority Whip, Rep. McCarthy (R-CA), has placed the bill on the calendar for Wednesday, June 7th, subject to the Rules Committee completing its work. Depending on the final number of amendments to be considered (if any), and the time provided for debate, it is possible that the bill could pass as early as Wednesday evening.

*John Mirvish is not admitted to practice law in the District of Columbia.

FinCEN itself says that there’s not much new in the guidance to money services businesses that the agency released last Friday (March 11, 2016) on agent monitoring (the Guidance).1 But MSBs that rely on agents should still review the Guidance carefully. The fact that FinCEN has decided to release this Guidance now shows that the agency is focused on the issue. And the agency does clarify some important points related to agent monitoring by MSBs.

To learn more about the Guidance, read the Mayer Brown Legal Update on it, available here.