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#1348750 - 02/24/10 10:00 PM CTR on Courier Service
melissajdl Offline
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Joined: Oct 2004
Posts: 13
Our bank offers a courier service to our customers. The courier picks up multiple deposits from these customers on a daily basis. Yesterday, there was one business that had a cash deposit over $10,000. When completing the CTR, do we include only the 1 business that had the cash deposit over $10,000 and the courier's name and info as the conductor? I'm asking because we were told once before that all of the businesses that the courier picked up that day had to be included which makes little to no sense to me. Can someone please clarify? Thanks!

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#1348873 - 02/25/10 03:23 AM Re: CTR on Courier Service melissajdl
rlcarey Offline
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Galveston, TX
If you are "offering" the courier service, I am assuming you are operating it as a mobile branch. As such, the deposit is made when the courier accepts the deposit and the person handing the deposit to the courier is the conductor.
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#1348916 - 02/25/10 01:26 PM Re: CTR on Courier Service rlcarey
Dani York, CRCM Offline
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Dani York, CRCM
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Posts: 3,663
TN
You will also want to check to see if your bonding covers a courier pick up cash deposits, especially ones with large amounts of currency. And make sure you have procedures in place to ensure that the courier is above reproach if a deposit comes up short (ie locked bags, log book, etc).
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#1348918 - 02/25/10 01:32 PM Re: CTR on Courier Service rlcarey
KYAuditor Offline
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Posts: 138
Kentucky
If the courier accepts the deposit, should they be getting the information needed to complete the CTR from the person who hands them the deposit? Should the couriers be informed by the customer if they are picking up a large cash deposit? Otherwise, if it is in a locked bag, how would they know that they needed to get the CTR information? Just curious as to how others are handling this.
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#1349028 - 02/25/10 03:38 PM Re: CTR on Courier Service KYAuditor
Flair Offline
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Posts: 44
We also offer courier services to our business customers. We have implemented a $7500 cash limit/day. This solved a lot of problems for us. We are, however, a small community bank. The previous FI I worked at had no limits, and used a third party courier service. We had a tough time getting the proper information for CTR.

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#1349161 - 02/25/10 05:15 PM Re: CTR on Courier Service Flair
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
So you are limiting their daily deposits to $7,500 but encouraging structuring?

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#1349586 - 02/26/10 02:28 PM Re: CTR on Courier Service devsfan
rdelgado Offline
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Originally Posted By: devsfan
So you are limiting their daily deposits to $7,500 but encouraging structuring?


I don't think it necessarily encourages structuring, it just limits the courier carrying amount. If a business expects it will bring in more than that, then this service would probably not be suited to it or would not be offered.

Or, cash deposits can still be made by a runner to the branch.

Limiting the courier amount does *not* mean the customer does not have other avenues to make their cash deposits.

It is the decision of the customer to use this service knowing the limitation on the cash deposit, it is not the bank saying the customer cannot deposit more than $7500 a day.

But it might be a fine line?

Our couriers are not supposed to pick up cash at all. If a customer of ours wants to use our service and are also cash intensive, they generally contract with an armored car service for the cash pickups and with our couriers for the check deposits.
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#1349689 - 02/26/10 03:50 PM Re: CTR on Courier Service rdelgado
Flair Offline
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Joined: Jun 2009
Posts: 44
rdelgado, that was our thinking exactly. We do have business owners who bring in their deposits when it is over the cash limit (usually after the weekend). They understand our thinking, and do not mind that they have to be inconvenienced once in a while. But again, we are a small town bank, in a smaller town and this is a free service extended only to certain businesses.

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#1374829 - 04/15/10 07:00 PM Re: CTR on Courier Service Flair
Rae Offline
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Rae
Joined: Nov 2003
Posts: 192
My bank also offers a courier service to bring deposits to a branch location, these deposits were originally intended to be checks only. We have recently discovered that most of these deposits do have cash included. Since we have offered this service for some time we would like to continue but realize we need some type of customer agreement. Does anyone have an agreement they are currently using with their customers they would be willing to share? I would greatly appreciate any guidance on this situation.

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#1374960 - 04/15/10 09:02 PM Re: CTR on Courier Service Rae
rlcarey Offline
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Galveston, TX
So, this service is not a mobile branch?
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#1375263 - 04/16/10 03:09 PM Re: CTR on Courier Service rlcarey
Rae Offline
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Rae
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Posts: 192
What is the definition of a mobile branch? I am relatively new to all of this and just want to make sure we are doing this right. Does accepting currency make us a mobile branch or is there more to it? When does our responsibility for the currency being transported start?

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#1375316 - 04/16/10 03:39 PM Re: CTR on Courier Service Rae
ComplianceGurl, CRCM Offline
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Posts: 498
We also have a courier service. When this service was created we notified the FDIC of our intent to establish a messenger service with the operation of a current branch. We then placed a notice in the local newspaper. It was technically a "Notice of Application to Establish a New Branch". Any persons wishing to comment on the notice had a specified period of time to file their comment with the regional office of the FDIC.

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#1375378 - 04/16/10 04:24 PM Re: CTR on Courier Service ComplianceGurl, CRCM
Rae Offline
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Rae
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Posts: 192
We are regulated by the OCC and have received permission for a courier service to transport deposits from the business location to the branch location. It was suppose to be for checks only however the branch has allowed currency to be deposited as well. When I found out about this and brought to to the attention of management they want to continue this practice with the inclusion of currency (OCC is fine with this) and I just need to know how to go about setting up agreements with the customers for transporting cash and was hoping that someone already had one they would be willing to share. I know there are other things involved with setting up the procedure but I was delegated the agreement portion of this project.

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#1375596 - 04/16/10 06:42 PM Re: CTR on Courier Service Rae
ComplianceGurl, CRCM Offline
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If you pm me Rae I would be more than happy to share what I use.

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#1375813 - 04/16/10 08:25 PM Re: CTR on Courier Service ComplianceGurl, CRCM
Rae Offline
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Rae
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Posts: 192
Thank you BSA Rookie, I will do that!

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#1375980 - 04/16/10 11:35 PM Re: CTR on Courier Service Rae
Dolly Nugent Offline
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Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
Wow! I would bet that the couriers that are picking up bags would be frightened to know that they might be carrying a large amount of cash. Personally, I feel it is irresponsible for a bank to put someone that is probably not making much more than minimum wage in this position. Customers that have the need to make large cash deposits should be set up on armored carrier service. Our courier service agreement expressly states "No Cash."
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#1376169 - 04/19/10 02:18 PM Re: CTR on Courier Service Dolly Nugent
ComplianceGurl, CRCM Offline
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We are in a very low risk area and the courier's we use are retired police officers. They are not frightened and believe me when I say they get paid very well, not just minimum wage. They are in unmarked cars along with no mention of a bank name on clothing, bags, etc. It is a very safe, discrete service that we offer to established, well known customers only.

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#1377339 - 04/20/10 05:41 PM Re: CTR on Courier Service ComplianceGurl, CRCM
Rae Offline
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Rae
Joined: Nov 2003
Posts: 192
BSA Rookie, just checking to see if you received my PM

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#1377839 - 04/21/10 01:04 PM Re: CTR on Courier Service Rae
ComplianceGurl, CRCM Offline
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Posts: 498
Sorry for the delay! You should have something in your inbox this morning. :-)

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