The February 2005 edition of the ABA Banking Journal has an article that states a CTR should be filed when a currency order arrives via an armored car service. Transactions with the Federal Reserve are exempted. If the currency order comes from the Fed, shouldn't a CTR on the armored car service be a none issue?

I read the same article and just asked the same question to the gurus too.

Can anyone clarify?

I read that article as well, and the issue with the armored car shipments is worded very strangely. Someone correct me if I am wrong, but I think what they are reffering to is cash deposits picked up from customers that are delivered via armored car, not Fed shipments. That is how I took it anyway.....

I have not read the article, but there is an Administrative Ruling pertaining to the armored car issue. 31 CFR Part 103; Appendix A to Part 103; Administrative Ruling 88-5 (Aug. 2, 1988). The holding is:


Financial institutions must file a CTR for the currency received by an armored car service from the financial institution's customer when the armored car service physically receives the cash from the customer, transports it and processes the receipts, even though the currency may never physically be received by the financial institution. This is because the armored car service is acting as an agent of the financial institution.

Mary Beth...Andy...Ken...haven't heard a response from any of you? My boss brought this article to my attention and he seemed very concerned. The article is very misleading and vague. As mentioned above, I was under the belief that shipments from the Federal Reserve Bank via Brinks (armored car service) were exempt and a CTR doesn't need to be completed. That article had us double guessing ourselves.

I don't have access to the article, but they have to be referring to deposits made directly from your customers to the Fed via an armored car. Cash shipments from the Fed to you are exempt, period.