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#1319462 - 01/07/10 05:36 AM Monetary Instrument Purchase Recordkeeping
Compgal Offline
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Joined: Feb 2006
Posts: 42
If an individual purchased a MI with $4500.00 in cash "on behalf" of another individual or entity, would the financial institution be required to keep record of that 3rd party "on behalf of" information as well as the purchaser information?

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#1319464 - 01/07/10 11:59 AM Re: Monetary Instrument Purchase Recordkeeping Compgal
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
No, only the purchaser's information is required.
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#1322168 - 01/11/10 08:37 PM Re: Monetary Instrument Purchase Recordkeeping rlcarey
KC Danimal Offline
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KC Danimal
Joined: Sep 2005
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Kansas City
I'm sorry if I'me being dense, but I get a different answer to this one each time I ask.

Is the "purchaser" always a human?

John Doe, president of Acme Enterprises comes to the bank and purchases a $5,000 cashier's check with cash from Acme Enterprises payable to Sam Spade.

Is John Doe the purcahser or is Acme Enterprises?
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#1322240 - 01/11/10 09:20 PM Re: Monetary Instrument Purchase Recordkeeping KC Danimal
BrendaC Offline
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BrendaC
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Sweet Home AL
Yes, the purchaser is the individual actually purchasing the item. In your example, Acme Enterprises is the remitter. John Doe is the purchaser.
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#1322362 - 01/11/10 11:53 PM Re: Monetary Instrument Purchase Recordkeeping BrendaC
Elwood P. Dowd Offline
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Elwood P. Dowd
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Posts: 21,939
Next to Harvey
Agreed. It's not an easy read, but the regulation intimates it is looking for the name of an individual. Some highly proficient external auditors automatically scan the list looking for the name of an entity. (What/who you list as the remitter on the check is up to you.)
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