All packages must be signed for by the consumer. Consumers are only able to receive orders at the billing address on their debit or credit card, which is verified using anti-fraud software. Consumers must use a debit or credit card for payment. Once this currency is restocked to normal levels, _ would fulfill the online customer’s order by mailing the foreign currency via FedEx directly to the person making the purchase.Ĭonsumers will be capped at ordering $2,999.99 worth of foreign currency per person, per day. In the rare event that both of those options fail, _ would place an order with one of its vendors to restock that currency to a level that would be acceptable for the historic demand. If _ runs out of a currency at the closest vault, the operations team that fills the order has access to view inventory at the other vault as well as _’s retail branches. _ maintains inventory levels based on historical data, seasonality, geographic region served and major events. _ currently maintains in two vaults an inventory of _ “major” currencies (_ country-specific currencies and the Euro, which is used in 19 countries) and _ minor currencies, all listed on _’s website. _ can fill orders of many different currencies. The service has not been opened to California consumers. _’s online foreign currency exchange service is currently being offered in some other jurisdictions. In addition to buying and selling foreign currency in its retail branches, _ offers customers the option of buying foreign currency through _’s website and having the currency delivered to the billing address of the customer’s debit or credit card. These branches provide an influx of foreign currency that _ can, in turn, make available for sale to customers and a wholesale network. _ buys and sells select foreign currency at these retail locations. Your client requests a determination by the Department regarding whether its proposed business activity-providing an online foreign currency exchange service-is subject to licensure under the Money Transmission Act (MTA). I have been asked to respond to your request, which you submitted on behalf of your client, _ (_). Thank you for your letter to the Department of Business Oversight (“Department”) dated May 12, 2020, Jconference call, and supplemental emails.
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