We have a bank employee who splits time as a courier and carpenter. He does pick ups on a daily basis. A customer gave him a series of large transactions which hit the CTR reporting threshold.

Would I have to use his information for Section B?

If the individual was acting as a bank employee in picking up the deposits, he doesn't get listed at all. The person who gave him the deposits gets listed in Section B.

Is your bank authorized to pick up deposits like this? In many states, that would be mobile banking, subject to branching rules. In any event, it's not a great idea to permit customers to entrust cash to such deposits, since your courier (I presume) is unarmed and not operating a secure vehicle. Over $10,000 in cash can be a very tempting target, particularly in these economically stressed times.

I hear you about the risk John. I and the security officer advised management on this very issue not too long ago, but the decision has been made.

Ok, I'll have to find out who gave him the deposits then.

Thank you.

For the future, if you are not able to keep customers from giving your courier reportable cash, equip your courier with a form for the customer's representative to complete with all of the Section B required data. Inform your customers that completion won't be optional.

That's actually a very good idea John. I think I'm going to do just that.

Thanks again for your help.

FWIW, we also have a part-time bank employee who picks up deposits. However, we do put a limit on the amount of cash our customers can give the courier in any given day.

As a side note, make sure that if this activity by a "bank employee" would be considered a mobile branch, you have the proper regulatory approvals, if required.