We are a credit union and we have two types of customers: credit union members and shared branching customers. Shared branching customers are members of other credit unions who can come into our branch and conduct transactions on their accounts. We have limited access to their account information and they are not our "members".

Regarding the regulation for keeping records for accountholders and nonaccountholders who purchase bank checks, cashier's checks, etc., involving currency in amounts over $3,000, I am unsure as to whether we would need to keep records for our shared branching customers in accordance with the nonaccountholders rules or the accountholders rules. (With nonaccountholders you need to keep additional information such as address, date of birth, etc.)

Any thoughts?

My presumption is that the reason the regulation calls for obtaining additional information for nonaccountholders is because, should the need arise, that information is not readily available after the fact, where with accountholders, it can be easily looked up if need be. In the case of our shared branching customers, that additional information is not stored on our system, but their social security number and credit union name is, so we could contact that institution, presumably, if we need to obtain that information for an investigation.

So the question is, do we treat shared branching customers like accountholders or nonaccountholders????

Thanks!

Treat them as non-account holders. If you attempt to wriggle out of this by saying "we can still point you to where the information is," you are subject to criticism by your regulator.

Law enforcement is not going to look kindly upon your "look over there at this other credit union for the information." That slows them down. It could lead to a referral to the Justice Department for not only failure to follow BSA rules, but also for obstruction of justice.

Thanks. It's funny how although I work in MIS, I seem to have recently taken the position of compliance "hall monitor".