Tell us
what you think
Our Sponsors
 |
Our Sponsors
|
Question & Answer
Question: Due to the potential liability involved, our institution has done away with our "exempt list". I have questions concerning the mechanics of filling out the Currency Transaction Report, Form 4789. We are trying to make the process of filling out the forms as streamlined as possible for the customers who were previously exempt.
One of our large cash customers deposits solely through a depository drop; several deposits daily. Is it necessary to fill out a 4789 for each deposit, or can we accumulate the amounts and report them as one cash transaction for the day? If we can accumulate the amounts, do we report the individual amounts as multiple transactions on the form? There are normally 7-8 drops daily, 15-20 after a weekend.
Another customer deposits mainly through the depository. However, usually he has one deposit daily made by an employee. Do we fill out a form for the employee on behalf of the business as part of the multiple transactions for the day?-Greg Shaver, Sr. VP-Citizens Bank of Batesville, AR
Answer: You sent us to the experts again. We talked to the Office of Financial Enforcement. Their answer is this:
If you have a customer that makes multiple cash drops a day, you may accumulate the amounts and report them as one cash transaction for the day. You should note on the 4789 that the cash reported was from four or six or however many transactions. It is not necessary to list the amounts-just the number of transactions.
As for the combination cash depository drops and deposits by individuals, the Office of Enforcement issues letters of permission allowing financial institutions to lump together drops and "on behalf of" transactions. Write for their letter, explaining the situation and they will respond. You will then have proof of the procedure for your examiners.
Address your letter to:
Office Of Financial Enforcement
Department of the Treasury
1500 Pennsylvania Ave. NW-Annex 5000
Washington DC 20220
Copyright © 1992 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 3, No. 4, 8/92
Rate This Article
Current Rating For the Feature:
| Total Ratings for this Feature: 0 |
|