We have a convenience store that has been a customer for awhile. They make their deposits, including cash, by sending "someone" to the bank who drops the bags off in the drive-thru (not the night deposit), and then drives away. The teller has stated that she does not know who it is that is leaving the deposits.

My question is in reference on how to complete the CTR. If there are multiple tickets and separate deposits, then "Multiple Transactions" should be marked. However, if one person is making these drop-offs, shouldn't we be gathering the information on the individual and be completing the rest of Section B if they are making these during regular, open banking hours (we're open until 8:00 p.m., six days a week)?

I think it's due diligence to know who it is. Branch Admin thinks I'm making a mountain out of a molehill (a southern expression!).

What is your opinion? Please, all opinions are appreciated! Thanks!

Apropos of nothing, waaaaay back my bank had in-store branches in larger Stop & Shop markets. I had a branch regularly failing to complete Section B, using "night drop" as the excuse. The teller must have thought that was a convenient way not to have to ask for ID info, but her plan went bust when I called the branch manager to remind him his branch didn't have a night drop.

John,
That's exactly what our tellers are doing, as I found out today. Then I questioned the timing of the deposits since we're open until 8:00 and the transaction numbers were sequential. I also think that this is the teller's way of making it "easy", but I have a problem with it.

So where do you fall on this fence? Leave blank and mark Multiple or should we know who is dropping off more than $10,000 at our drive-thru?

We don't take merchant deposits through the drive thru. We'd make them come into the bank or set them up so they really could use the night drop.

Just my opinion, but I view a drive thru deposit the same as an over the counter deposit. I think you need to file the CTR with the conductor information, assuming you can get it.

If you don't have a policy like the one BSAdiva describes, have a conversation with the customer and explain that you must get the information. Then, if the drive-thru conductor supplies you with the information you need, you can decide whether to allow him to continue his "drop and run" pattern. If he won't cooperate, you'll have to ask the depositor to send someone in a more cooperative frame of mind.

Considering the potential time involved in verifying a business deposit with cash, I would have assumed that no one did. All three of the banks where I worked had signs on the drive thru telling commercial custoemrs to come inside...

As far as allowing "drop and run," not a chance, not a snowball's chance. Those tellers who are "saving time" are the ones who will be under suspicion if the getaway driver does not wait until the cash portion of the deposit is verified and there is a discrepancy. The deposit would be placed under dual control (just like the night drop) and the business would be notified to send someone back.

From my perspective, the point is moot, but, yes, you would need the getaway driver's ID if you allowed the practice.