The Critical ID-Number Update for Florida Check Cashing Licensees

If you operate as a licensed check-casher in Florida under the Office of Financial Regulation (OFR), you are subject to follow Florida Chapter 560 and the corresponding Administrative Rules 69V-560, as such, this update is essential. On July 31, 2024, the state changed the numbering scheme for customer identification numbers. That means every customer who was listed prior to that date and whose record was renewed on or after that date may have received a new ID number. Failure to update your internal software to reflect the new number can expose you to violations of state recordkeeping and reporting rules.

Why does this matter?

Under Chapter 560 of the Florida Statutes, check-cashing licensees must maintain records and enter specific data for transactions in excess of $1,000 per customer per day. The identification number presented by the payee (or conductor) is among the required data elements. With the database requirements, you must track that change to avoid mismatches between the customer’s new information and the data in your point-of-sale software to ensure you are transmitting accurate information.

What changed on July 31 2024?

The Florida database numbering scheme was amended to include four random numbers as part of the ID number structure. That means that any customer in your software prior to July 31 whose renewal occurred on or after that date will likely have an updated ID number. If your check-cashing software still reflects the old number, then you risk entering inaccurate or outdated data when you submit transactions that trigger the >$1,000 daily threshold.

Who is impacted?

This issue affects licensed check-cashers in Florida. Whether you operate one location or multiple, if you handle payment instruments and cash them for customers and you exceed the $1,000 aggregate threshold in a day for the same person, you must report the transaction in the state database. Any legacy customer whose ID has changed is more than likely impacted.

What must a licensee do?

1. Run a customer-database review: Identify all customers whose records pre-date July 31, 2024, and who had renewals on/after that date.

2. Match ID numbers: For each such customer, verify the current database ID number assigned under the new scheme and update your software and customer files accordingly.

3. Update your check-cashing software: Ensure your system has accurate as well as the most recent information. If the information has changed, make sure you properly enter it into the proper field in the customer file.

4. Train staff: Inform operations and compliance personnel about the change. Emphasize that old ID numbers must not be used for new transactions.

5. Audit for accuracy: Perform a mini audit of transactions after July 31 to confirm that your entries into the database reflect the correct, current customer ID numbers.

6. Document the process: Maintain documentation of this review and update. Should the OFR or auditors request evidence, you’ll want to show your proactive steps.

Risks of non-compliance

Failing to update to the new ID scheme can lead to:

• Incorrect database entries for transactions > $1,000, which could trigger inquiries or enforcement.

• Violation findings during an OFR exam of your AML/BSA/records program.

• Potential reputational and operational risks if the state flags systemic errors in your database entries.

Recommended compliance language

In your AML/BSA or compliance manual for your check-cashing business, include a section along these lines:

The licensee shall maintain current customer identification and database ID numbers. For customers whose Florida Check Cashing Database ID was renewed on/after July 31, 2024, the licensee shall verify the updated ID number incorporates the post-July 31 scheme. The licensee shall update its internal software and files to reflect the new ID number prior to accepting any further cashing transactions for that customer. The licensee shall independently review its customer master list at least annually and whenever database scheme changes are announced.

Why this fits into an MSB-compliance program

Your Florida check-cashing activity sits within the broader framework of being an MSB under Florida law. The term “money services business” includes a check casher. Proper recordkeeping and database reporting are foundational to your compliance framework. Ensuring accuracy of customer ID numbers in the state database is simply one part of that program, but a part that can be overlooked if you assume the ID numbers remain static over time.

Final thoughts

If you are a Florida check-cashing licensee you cannot assume your customer database is up to date simply because renewals have occurred. The scheme change effective July 31, 2024, means a subset of customers will have new ID numbers. Ignoring this change or delaying the update exposes you to reporting errors and regulatory risk. Now is the time to email your software vendor, pull your customer list, and verify IDs. Proactive compliance helps you avoid the “surprise” of finding violation counts during a future OFR exam. If you find yourself unsure how to map old vs. new IDs, engage your compliance consultant to assist. The goal is simple: correct IDs in your internal system = accurate state database entries = lower regulatory risk.