On January 19th, the Financial Crimes Enforcement Network posted its November 20, 2009 Ruling on whether the bill payment activities in which certain companies engage make them money services businesses under the Bank Secrecy Act; whether such transactions processed through automated clearinghouse systems are subject to the Funds Transfer Rule and the Travel Rule; and, if both questions were to be answered in the affirmative, whether FinCEN would consider granting regulatory relief under the Funds Transfer Rule and the Travel Rule. FIN-2009-R004.