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#1302858 - 12/10/09 06:14 PM Monetary Instruments purchased in cash
BowlingQueen Offline
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Joined: Mar 2007
Posts: 2,920
Wisconsin
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?
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#1303887 - 12/11/09 07:21 PM Re: Monetary Instruments purchased in cash BowlingQueen
BowlingQueen Offline
Power Poster
Joined: Mar 2007
Posts: 2,920
Wisconsin
Bump.


Is there anyone who has any insight on this for me?

Any help would be greatly appreciated.. smile
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#1303938 - 12/11/09 07:54 PM Re: Monetary Instruments purchased in cash BowlingQueen
Kelsey D Offline
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Joined: Aug 2006
Posts: 516
Ohio
At my bank, we allow customers to use cash to purchase monetary instruments without requiring them to deposit the money into an account first. If the total cash used to purchase monetary instruments aggregates to $3000 or more in one day, every transaction involving cash, regardless of the amount, shows up on my report. I look at cash purchases between $1000 and $2999 to look for multiple purchases by the same person and somtimes other transactions that look unusual on my report. If we required customers to deposit the money into their account, I would see a cash in to their account on my report, but I wouldn't see on that report that the money was then debited for the purchase of a monetary instrument. Looking at every account that had more than $3000 in to see if there was an offsetting debit for a monetary instrument would not be feasible in my case, so requiring them to deposit the cash first would be a reporting nightmare for me. Sorry I'm of no help!
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#1304062 - 12/11/09 09:03 PM Re: Monetary Instruments purchased in cash Kelsey D
BowlingQueen Offline
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Joined: Mar 2007
Posts: 2,920
Wisconsin
Well not exactly NO help wink ......but then I think we would then have to decrease the dollar amount threshold on the large currency report from $3,000 (which is listed by TIN) to some lesser amount so smaller cash purchases would show up. Then I would have a much, MUCH larger report to look at every day.
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#1304093 - 12/11/09 09:15 PM Re: Monetary Instruments purchased in cash BowlingQueen
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
My large currency report is set at $3000 and aggregated by TIN. Our monetary instruments are sold from accounts with the bank's TIN, so when the total for the day aggregates to more than $3000, each transaction involving cash shows up. Make sense?
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#1304164 - 12/11/09 09:55 PM Re: Monetary Instruments purchased in cash Kelsey D
BowlingQueen Offline
Power Poster
Joined: Mar 2007
Posts: 2,920
Wisconsin
Gotcha.

Thanks.
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#1306463 - 12/15/09 06:50 PM Re: Monetary Instruments purchased in cash BowlingQueen
NewTooBSA Offline
Platinum Poster
Joined: Nov 2005
Posts: 568
Texas
We only sell MI to customers and our automated tracking system includes an area to add the account number. It breaks it down so we can enter the types of documents used to purchase; cash, withdrawal, check, etc. That eliminates the need to deposit the cash first. It takes the teller a little longer to complete the sale but saves the back office time and is easier to track the cash.

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#1306997 - 12/16/09 01:17 PM Re: Monetary Instruments purchased in cash NewTooBSA
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,959
Galveston, TX
Are you sure you only sell to customers? What about authorized signers on business accounts or trustees on trust accounts. They are not customers as they are not the "deposit account holder". Loan only customers also present a challenge.
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