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The $3000 Rule-It's Just Around The Corner

One of the things that makes life interesting for the compliance officer is the total unpredictability of the regulators.

We have known for some time that the "$3000 Rule" is coming, and there is no good reason for the fact that it has not yet arrived!

In case you have been visiting another planet and haven't heard about "The Rule", it has been proposed that if a financial institution sells a bank check, cashier's check, traveler's check, or money order to an individual for $3000 or more, it must keep a record of the transaction.

This record, which must be maintained in a central location in the institution for five years, must contain certain pieces of identification (positive identification-which will be defined by the regulation) on both customers and non-customers.

We've known that this recordkeeping monster has been on its way for well over a year.

In fact, numerous institutions are already keeping the records.

But for some mysterious reason, "The Rule" has not (at least as of the date of this article) become official.

Could it be that our esteemed government officials are finding it difficult to tell us what positive identification is?

In any case, be on the alert for the regulators to come riding through crying, "The $3000 Rule is Coming! The $3000 Rule is Coming!"

Copyright © 1990 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 1, No. 2, 2/90

First published on 02/01/1990

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