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#1159442 - 04/07/09 09:48 PM Non-Customers
Texas53 Offline
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We were told to set up name and address accounts for non-customers cashing checks. Does anyone else set non-customer for tracking the cash?

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#1159493 - 04/07/09 11:48 PM Re: Non-Customers Texas53
rlcarey Online
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Told by whom?
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#1159678 - 04/08/09 02:16 PM Re: Non-Customers rlcarey
Texas53 Offline
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Our data processing center. They said that we have to track all cash transactions. The only way to do that is by having an name and address set up on our system.
Last edited by Texas53; 04/08/09 02:18 PM.
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#1159747 - 04/08/09 03:02 PM Re: Non-Customers Texas53
Big Dog Offline
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We do, but it's not an actual CIF. Our teller system captures the information for aggregation purposes. Once we have the info on the non-customer, we don't ask again, just verify that there are no changes.
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#1159752 - 04/08/09 03:05 PM Re: Non-Customers Big Dog
BrendaC Offline
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My prior bank could do that through the teller system as well. We selected a specific dollar amount to trigger the record keeping. We did not maintain a record for smaller cash transactions.
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#1159777 - 04/08/09 03:19 PM Re: Non-Customers Texas53
mck401 Offline
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not here, nor do we want to clog our data base with non customer information.
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#1160151 - 04/08/09 07:32 PM Re: Non-Customers mck401
What?? Offline
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What??
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I agree, they are not your customer, why would you do that?

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#1160168 - 04/08/09 07:44 PM Re: Non-Customers What??
BrendaC Offline
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This is a MAJOR hot button for regulators coming out of Miami.

The info was not maintained in our core system, it was a separate info base in the teller system. It served two valuable purposes: 1) streamline CTR automation where multiple transactors were involved; and 2) respond to regulatory encouragement to enhance our ability to aggregate cash transactions conducted by same person.

I have seen some banks that actually required tellers to go to the bank's intranet to complete spreadsheet when any person conducted a cash transaction of $1000 or more. I consider that burdensome. I do think it is reasonable, however, to automate a procedure for aggregation of, let's say, $3000 or more in cash if it can be done in a less intrusive way. It is often the same parties conducting these transactions and once their info is in the system, you can move through the process very efficiently.
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#1160378 - 04/09/09 12:24 AM Re: Non-Customers Texas53
rlcarey Online
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Originally Posted By: Texas53
Our data processing center. They said that we have to track all cash transactions. The only way to do that is by having an name and address set up on our system.


Why would your data procesing center be charged with or allowed to dictate something like this. Who is your BSA Officer??
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#1160420 - 04/09/09 03:51 AM Re: Non-Customers rlcarey
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I've seen some credit unions that require fingerprinting for non-customers when cashing checks...

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#1160422 - 04/09/09 04:30 AM Re: Non-Customers KYCspcialsts.com
Texas53 Offline
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I think it is good, because you can track if someone is cashing checks at different branches on the same day. It will also show if they start a pattern of cash checks for large amount. We would have a cash history on them. All my BSA reports will be correct. We have decided to give non-customers that come in on a regular bases an account number. If it is a one time thing we will not. Once the person is in the system we can just pull up their name and all there information will be there with their ID.

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#1160456 - 04/09/09 12:50 PM Re: Non-Customers Texas53
Bagweaver Offline
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SW GA
We don't cash checks for non-customers except those drawn on us. We also require that all non-customers put their fingerprint on the front of the check - even those that come in every week to cash a check on us - no exceptions.
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#1160482 - 04/09/09 01:15 PM Re: Non-Customers Bagweaver
Kitcat19 Offline
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Florida
Texas53, We track cashed item transactions via the account number/TIN the check was drawn off--we have trained employees to be aware of non-customers cashing large item checks (over $3,000.00)--because they may end up with a reportable CTR-- (This is true for non-customers/account signers bringing deposits on behalf of customers). Additionally our teller system automatically calls for CTR info in any cash trans. >$7,000.00. It would be insanely burdensome for us to create account numbers for non-customers. I'm afraid I don't see the benefit vs. manpower advantage for the scenario you presented.

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#1161191 - 04/09/09 10:57 PM Re: Non-Customers Kitcat19
Dolly Nugent Offline
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Southern California
Our teller system also permits this. It can be very useful and a time saver if your business customer routinely sends an employee that IS NOT a customer to the bank to make deposits. We use it to streamline the CTR preparation process.

Our teller system is separate from our core system. We are NOT building a CIF for the non-customer.
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#1163398 - 04/14/09 08:32 PM Re: Non-Customers Dolly Nugent
Texas53 Offline
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The data center did not say we had to do this, but that we could if we wanted to track all cash transactions. We only have to set them up once. For an infrequent non customer we will not do this. Only the ones that come in all the time. Does everyone check non-customers against the OFAC? We do this also, and once we set them up on our system we don't have to worry about that.

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