Question & Answer
Question: We have a customer who is putting cash in a safe deposit box. If he tells us that he is doing so, we have two questions.
(1) Is it legal to put cash in a safe deposit box?
(2) Should we file a Currency Transaction Report?
Answer: The answer to question number one is easy-there is nothing illegal about putting cash in a safe deposit box. The Internal Revenue Service is not pleased about cash being stored in this way, but customers often store coin collections or currency in this fashion. Fire insurance companies would prefer policy holders that keep currency in safe deposit boxes instead of at home.
The answer to number two is tougher. If the customer reveals to you that he is storing the cash in the safe deposit box in order to deposit a little at a time, and so avoid reporting, it certainly can be construed as structuring. In that case you may want to file a suspicious transaction report.
But, on the other hand, if there is no transaction, and no intent to structure, there is nothing to report.
Copyright © 1991 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 2, No. 1, 1/91
First published on 01/01/1991