I'm with JOhn on this one - the bank determines what information they need to complete the transaction, this is not something the customer can choose to provide or not provide. No information? Then no transaction. It really is not a difficult choice.

Document the phone call and file it according to the instructions you received. Go on to what's next.

Beyond that, the response you received is completely, totally ridiculous. If either rlcarey or I said that we'd be at one another's throats. There is nothing about your situation that is analogous to the "armored car" mess.

The "armored car" reference came from me not them. But I did use that comparison with them while on the phone and that is how I was told to complete the CTR. I guess it's because they're a public entity.

And it is difficult when it involves this type of customer that we've maintained a relationship with for many years and legal counsel gets involved and they all know "their rights."

Believe me, I wasn't very happy about finding out that they are apparently correct in that they don't have to provide us the information.

I think I found what they were quoting:

http://www.fincen.gov/statutes_regs/bsa/bsa_faqs.html

question 21

I will concede that that response is official and that it is pretty broad in its application to "government officials" conducting transactions as part of their "official duties." It's too bad it only provides and example related to law enforcement. It is clear, I think, that the whole think pivots on whether the transaction is being conducted on behalf of the government agency/unit, and not on behalf of an individual.