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#1137708 - 02/27/09 08:12 PM Savings Bonds Monetary Instruments?
ShannonC Offline
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I recently utilized the bankers tool section of BOL for BSA training. I found a new power point presentation posted January 13, 2009. I found the presentation to be well put together and easy to understand. However, I noticed on the slide discussing the sale of monetary instruments they had included "savings bonds" as a monetary intrument. I had always thought they were not classified as monetary instruments. I did some additional research on BOL found that Ken Golligher had posted a reply to whether savings bonds were monetary instrument in October 2003 and John Burnett had posted a similar reply in February 2004.

Has something changed since 2003 and 2004 that would make savings bonds monetary instruments? I am getting ready to train my staff and love using the BOL tools, but want the correct information to be given to staff.

I have "googled" the defination of monetary instrument and also reviewed the BSA exam manual and cannot find a definative list of what a "monetary instrument" is.

Do you classify savings bonds as monetary instruments? Thanks for your help.

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#1137771 - 02/27/09 08:41 PM Re: Savings Bonds Monetary Instruments? ShannonC
rlcarey Online
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No - the regulation limits this to: bank check or draft, cashier's check, money order or traveler's check. Savings bonds are not negotiable so they do little good in the transfer of illicit gains.
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#1369699 - 04/06/10 03:16 PM Re: Savings Bonds Monetary Instruments? rlcarey
Islandgirl Offline
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If you are completing a CTR on Savings Bonds cashed over $10,000, would you mark "Other" and put "Savings Bonds" on the line next to it? and not mark Negotiable Instrument Cashed?

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#1369840 - 04/06/10 04:51 PM Re: Savings Bonds Monetary Instruments? Islandgirl
John Burnett Offline
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Correct. A savings bond is not a negotiable instrument.
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#1500277 - 01/26/11 02:08 PM Re: Savings Bonds Monetary Instruments? John Burnett
GrannieTwo Offline
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This topic came up during training last night and it drew a question I wasn't sure on... Should you CIP a non customer who wants to purchase or redeem a Savings Bond? The BSA officer in me says yes, but I can't locate anything to support my thoughts. One additional question, don't I recall that a bank can redeem bonds up to a $1000 in one days for a non customer? For ex: if you have a non customer come in with a stack of bonds to redeem, the bank can redeem just up to $1,000, correct? Thanks!!!!
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#1500280 - 01/26/11 02:14 PM Re: Savings Bonds Monetary Instruments? GrannieTwo
Elwood P. Dowd Offline
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A person redeeming bonds is not opening an account. CIP does not apply.

(1)(i) Account means a formal banking relationship established to provide or engage in services, dealings, or other financial transactions including a deposit account, a transaction or asset account, a credit account, or other extension of credit. Account also includes a relationship established to provide a safety deposit box or other safekeeping services, or cash management, custodian, and trust services.
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#1500281 - 01/26/11 02:14 PM Re: Savings Bonds Monetary Instruments? GrannieTwo
rlcarey Online
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Look at the CIP definitions of customer and account in 103.121. Savings Bond transactions do not meet either definition. You are correct on the non-customer limit.
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#1500288 - 01/26/11 02:28 PM Re: Savings Bonds Monetary Instruments? rlcarey
edAudit Offline
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Also review the wording of you policy and procedure. To end the confusion your policy and procedure should be clear to the limits and Id requirements for Savings bonds.
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#1500289 - 01/26/11 02:30 PM Re: Savings Bonds Monetary Instruments? rlcarey
GrannieTwo Offline
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Thank you for your responses, but..... lets say someone steals some savings bonds, walks into our bank and we redeem them without obtaining any ID, the government won't come back on us and say how come you didn't CIP them?
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#1500292 - 01/26/11 02:35 PM Re: Savings Bonds Monetary Instruments? GrannieTwo
GrannieTwo Offline
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EdAudit - That's the rub, we don't address savings bonds in BSA & in presenting a BSA training last night, savings bonds came up. Common sense tells me, CIP everything. Or am I hearing CIP may not be required but if my bank chooses to CIP non customers who are purchasing or redeeming bonds, then we must follow our policy and CIP them?
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#1500299 - 01/26/11 02:43 PM Re: Savings Bonds Monetary Instruments? GrannieTwo
Kathleen O. Blanchard Offline

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Look at the definition of customer for CIP in BSA. Savings bonds are not an account of the bank so the holder is not a bank customer if all they have are savings bonds they want cashed.

You should ID when conducting transactions, but don't confuse it with CIP, which includes validation of some elements of identification.
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#1500301 - 01/26/11 02:44 PM Re: Savings Bonds Monetary Instruments? GrannieTwo
Elwood P. Dowd Offline
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There is no reason to address savings bonds in your policy. Your common sense should tell you not to CIP anything that does not involve a customer opening an account.
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#1500308 - 01/26/11 02:47 PM Re: Savings Bonds Monetary Instruments? Elwood P. Dowd
GrannieTwo Offline
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KayBee, you hit the nail on the head, I was confusing CIP with obtaining ID. Thanks to everyone.
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#1500316 - 01/26/11 02:57 PM Re: Savings Bonds Monetary Instruments? GrannieTwo
rlcarey Online
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Originally Posted By: GrannieTwo
Thank you for your responses, but..... lets say someone steals some savings bonds, walks into our bank and we redeem them without obtaining any ID, the government won't come back on us and say how come you didn't CIP them?


They won't ask why you didn't CIP them, but that doesn't mean they won't come back at you for not following the savings bond redemption requirements. It is two different animals. You need a copy of this:

The Guide to Cashing Savings Bonds (PD P 0022), explains acceptable types of identification and
provides a step-by-step question and answer approach to cashing bonds. The guide is meant to
simplify the redemption process for tellers, and eliminate errors that might result in liability
findings against their financial institution.
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#1500323 - 01/26/11 03:05 PM Re: Savings Bonds Monetary Instruments? rlcarey
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As the id requirements can be different for Savings Bonds, CTR, and Cash advances, in banks I have worked, I have seen in the Bank/Teller Operations Manual (Not BSA) Identification section for the requirements including the limitations on cashing. The guidelines for savings bonds followed the Guide to Cashing Savings Bonds as Randy mentioned.
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