My question focuses on CTR reporting, night drops, and what constitutes "deposit location".

Here is the scenario: Well known businesses deposit cash at the night drop box at our branches. When the bankers open the next day, the teller gives them a provisional credit for the amount on the deposit slip, but due to volume and staffing, will not actually count the cash. A third party then stops by and picks up the cash, along with cash at several other locations. Hypothetically, one of these businesses will have multiple night drops at different locations. The cash is taken to a central repository, where it is counted and then it is decided if a CTR should be filed.

Question: Is the actual "location of deposit" (on the CTR form) considered the branches or the central location where the cash was counted and the CTR was initiated? If it is the centralized location, then it would seem only one CTR would be required. Otherwise, our back office will have to trace back each deposited amount at every branch.

Thanks!

I've been fielding questions about CTRs for over a decade and this is a first! And by the way, congrats and welcome on the occasion of your first post in our forums, "thestout15."

My gut tells me all of the deposits are processed at the central facility even if the checks from the deposit, etc., are processed at the respective branches. But I strongly recommend that you contact FinCEN's Resource Center by email or phone and lay out the question in detail to them, taking careful notes if the response is given by telephone.

The contact information for the Resource Center is at https://www.fincen.gov/contact
It includes two phone numbers (one is toll-free), an email address, and a webform you can use to generate an email to them.

We will all be interested in hearing what you learn, so please drop back into this conversation to share it with us.

thestout15, Used to work at a bank that did this (they still may). Customers used disposable plastic bags (separate compartments for deposit ticket & checks vs. cash). Tellers removed tickets/checks and verified cash stated on ticket matched that recorded on bag. Deposit was processed with provisional credit for cash; then bags with cash still sealed were picked up by armored carrier for verification. Teller system aggregated totals for CTR filing, and locations on CTR were based on where the deposit was initially processed. Hope this helps.

Interested to see what FinCEN says. If you don't get a response then document your decision and be consistent.

thestout15, Used to work at a bank that did this (they still may). Customers used disposable plastic bags (separate compartments for deposit ticket & checks vs. cash). Tellers removed tickets/checks and verified cash stated on ticket matched that recorded on bag. Deposit was processed with provisional credit for cash; then bags with cash still sealed were picked up by armored carrier for verification. Teller system aggregated totals for CTR filing, and locations on CTR were based on where the deposit was initially processed. Hope this helps.




Would these provisional credits be given to any customer who uses the night drop? For example, would a well-known and large entity get the same treatment as an individual depositing a stack of cash?

The credit to the cash intensive businesses was provisional because the tellers didn't verify the cash - the armored carrier did, and the provisional credit was disclosed in the night deposit contract. The bank had sealed all envelope slots a while back, so individuals didn't deposit through the night drop. Wasn't a big deal given their accessibility to deposit-taking ATMs.

These days, fellow Cape Codder, I have to wonder if those plastic bags are recyclable! I remember when the concept was introduced a long time ago. We polled some business customers who didn't want to change their ways. We kept the old key-locked deposit bags. Of course that was at least 30 years ago, and customer habits may have changed since I was last a teller.

Gee John, now I feel old. . . Actually the bags really helped the heavier cash branches be more efficient, and customers walking in with night bags liked them because of the time saved getting their deposits processed. It also eliminated those hated over-the-counter "drop-and-run" bags. More reluctant customers were offered an initial supply free. If I recall correctly, that bank also charged for currency verification, and the charge was less if the deposit was in one of these bags. As you say - a long time ago.