We have the provision in our CIP policy that for elderly we may accept a secondary form of ID as the primary. In this case, the bank accepted a social security card.

We have a senior executive who is close to this client. She gave him checks payable to her for $12,000 that he brought into the bank to cash and he delivered them money to her. She endorsed the checks and he endorsed also.

I'm leaning towards that he was acting as a bank courier on this transaction (except I hate that he endorsed the checks) and that the CTR should be filed just as if the elderly customer came into the bank to cash the check.

The other problem is we do not have a primary ID for this customer. I don't see in the CTR instructions where you can waive due to the customer being elderly or disabled. I've asked the executive to obtain a copy for our records but he's not sure if she has a primary ID.

Am I on the right track?

On ID, you can check box 14 d (old form) and put other and type her identification there.

Also ,I would think that the person who got the cash should sign the check (executive), but put the elderly woman as the beneficiary and the executive as the conductor.

Under the old form, you can choose Disabled/Elderly with no ID under 14d. Box 14d has a drop-down with this option.

Banks are not allowed to accept lesser ID on a CTR from the elderly or disabled on a case by case basis. To do it, the issue must have been addressed in bank policy in advance.FIN 1992-R001

You simply cannot "fix" this in arrears, but you need to send your senior executive back to get some kind of identification. As he endorsed the items, I would list him on the CTR as a person on whose behalf the transaction was conducted along with her. He's not a mobile branch; he did this as an individual, not a bank employee.

He made some bad decisions here...

Thanks everyone for your input. Ken - if I list our executive as a conductor, I would use his identification for the CTR and really not need hers then, would I? She would just be for the benefit of. And wouldn't I select Person conducting transaction for another for my executive and person on whose behalf the transaction was conducted for the customer?

And in the future, we do offer courier service in that area, and they do deliver and pick up cash. Wouldn't it be alright to just treat this as a teller transaction? No endorsement by the executive, just by the customer.

Correct -- you would not need her ID since she was not present. Also, you've said that your policy does allow for modified ID requirements for her demographic.