It is the practice at our bank to "encourage" the customer to deposit cash in an account to facilitate the purchase of a monetary instrument, in order to ensure a "paper trail" for BSA compliance. We do this for any dollar amount, with the reasoning that our Currency Transaction reports will not pick up dollar amounts (in or out) of less than $3,000 (single or aggregate).
If a customer comes in to the bank in the morning and purchases a $1,500 cashier's check in cash and later goes to another office to purchase, say, a $2,000 Visa Travel Money Card, if we didn't make the customer deposit the cash, how are we going to satisfy the aggregating requirement when there is virtually no way for our system to catch that?
We have had a "few" complaints that this procedure is causing customers to become upset, especially when the purchase involves less than $100.
We have a "special" log form that can be used ANY time we make an exception to our procedure of depositing the cash to ensure that we have satisfied the identification, aggregation and recordkeeping requirements for BSA. Yet still, I was called on the carpet by our bank president (in the middle of a training session) that we need to change our procedure because of said complaints. I think doing so will cause more harm than good....in the long run.
What do you all do to satisfy the requirements and yet promote goodwill with the customer on this issue?
Nothing changes, if nothing changes. (from a good friend of mine)