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#1526481 - 03/24/11 04:07 PM Structuring question - teller response?
AuditorK Offline
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Joined: Feb 2003
Posts: 962
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If we have a customer ask a teller, "What amount can I deposit to avoid the bank from reporting the cash deposit?" - what can that teller say? Can we just tell the customer that the bank is required by law to file a report on cash transations greater than $10,000 and say nothing more? I want to make sure we aren't facilitating or instructing the customer on structuring.

I know we need to file a SAR - especially since the customer proceeded to make two cash deposits of slightly less than $10,000 over the next two days.

One thing this has done is prompted us to provide each branch with a bunch of copies of FinCEN's CTR brochure to hand out in the future when questioned.

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#1526484 - 03/24/11 04:08 PM Re: Structuring question - teller response? AuditorK
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
The standard response is to provide the brochure and avoid verbal discussion of the limits.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1526487 - 03/24/11 04:11 PM Re: Structuring question - teller response? Kathleen O. Blanchard
AuditorK Offline
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Joined: Feb 2003
Posts: 962
PA
That's what I assumed the correct answer would be. What did banks do before the brochure came out?

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#1526493 - 03/24/11 04:18 PM Re: Structuring question - teller response? AuditorK
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
There were (and are) brochures you can purchase that are a bit less explicit (don't mention any required reporting other than CTRs.)
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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