Notes

Casinos & Sports Betting
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Benefits
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Other Acams Sites
Three days after Smith's death on March 17, 1885, the hotel burnt down. Darby and Lyman formed the Arrowhead Hot Springs Company and built a new hotel for $150,000 in 1886. After it was expanded to 120 rooms it was the largest hotel in the San Bernardino area until it, too, burnt down on July 4, 1895.
Thus, to the extent that we would make any of the proposed changes to the reliance provision, we believe it would be important to make the same changes concurrently to the applicable CIP provisions, which would require joint rulemaking. The first limitation reflects the additional structural limitation described in our discussion of these account types that makes them a low risk of money laundering, and therefore a necessary characteristic to qualify for these exclusions. FinCEN has learned that most exempted accounts will not be affected by this limitation based on comments and subsequent inquiry into these financial products. This requirement was also drafted to allow financial institutions covered by the provision flexibility in implementing it.

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