Case No. IA-18450

Date issued: Jan. 28 2013

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TURBOFAC Commentary (206 words)

Notes:

1) This request was sent shortly after the issuance of the general license at 560.551 (Student loan payments from persons in Iran authorized). The GL provides that "United States depository institutions and private loan companies are authorized to engage in all transactions necessary to collect, accept, and process student loan payments from persons in Iran or ordinarily resident in Iran" (emphasis added).

It is unclear exactly what the applicant was unsure about. One possibility is that there was uncertainty as to whether the U.S. bank could process the loan payments "in its capacity as a service agent," rather than an account party or actual holder of the student debt. Another is that Citi was concerned that processing the payment “in its capacity as a service agent,” rather than in its capacity as a “United States depository institution[],” would mean...