Our core processor now has the abililty to aggregate non-customer transactions if the SSN for the conductor is entered at the time of the deposit for all transactions regardless of amount. This has caused some upset business customers! We used to just get the conductor's SSN if the transaction(s) triggered a CTR based on the business EIN.

Does anyone else get the SSN for all conductors regardless of the transaction amount (and filing CTRs on the conductor when appropriate), or are you only getting the SSN when you know a CTR is required?

What is your threshold amount; i.e. do you require it on all cash transactions or only those above $XXXX?

We ID the conductor (including SSN) on all cash transactions $2500 or higher. The transactor info is saved in the teller system. So, if it's someone that makes frequent transactions for their employer, we only need to request it once and enter it into the teller system. The next time the teller will simply ask their name if the teller doesn't remember them, find them in the system, and continue with the transaction.

Right now we are doing this on everything, which is part of the issue. I think a threshold amount would be a good idea.

The number of banks doing it is limited to some extent by the fact that you have to have the data processing capability. You might want to talk to some banks that use the same vendor you do and see how they have set things up.

I would suggest $3,000 as a threshold. That amount triggers some unrelated responsibilities in connection with the sale of monetary instruments and it should be familiar to your employees.