We will shortly be adding intra-day cash aggregation by primary TIN owner to our teller system, with a prompt to the teller to gather conductor info when the aggregate exceeds $10,000. We're also adding a prompt to require tellers to gather conductor info on individual cash transactions <$10,000 (haven't yet decided on the threshold). Am developing training materials and looking for suggestions on best response to conductors questioning the need for CTR info on the smaller dollar transactions (e.g. they're conducting a $250 currency exchange on behalf of an entity that deposited >$12,000 thru the night drop). Would appreciate any responses. Thanks.

A sign at each location where cash is received: Our personnel may require identification for any transaction including those involving currency.

I think I would train the tellers to shrug and say, "I don't know. It's part of our effort to tie together multiple cash transactions on the same day. Here's a brochure that explains it a little bit. Would you like to talk to my supervisor?"

Thanks, Ken. Much appreciated.

You're not the only one doing this...I was hoping you would get more responses.

Folks?

We have the teller line staff give out FinCEN's CTR Reference guide.

http://www.fincen.gov/whatsnew/pdf/CTRPamphletBW.pdf

We obtain conductor information on all cash transactions of $7,000 or greater and have done so for many years. If the customer inquires why, the response is that it is bank policy.

At my previous bank we obtained conductor info on cash transactions of $5,000 or more; this was in place for quite a few years. At my current bank (which is much, much smaller) we stick with the $10,000 threshold.

When asked about the need for the ID, our tellers usually stated that it was bank policy (at the previous bank). Here we offer the pamphlet.

THanks for the responses, folks.