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#1815780 - 05/20/13 04:34 PM Book Buyback Sub-Contractor
2old2care Offline
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Joined: Oct 2006
Posts: 710
PA
Overview:

Customer (Individual) comes into bank to buy a cashiers check with funds received from a College Book Buy Back program.
Customer has a personal checking account with the bank.
Customer deposits cash and then withdraws cash to purchase a Cashiers Check.
CTR is completed with the customer information on file.

Question:
I have dealt with the book buyback programs in the past. I questioned the CTR being made out with the individual name. At a prior bank the company who sponsors the buyback was listed on the CTR.

I asked some questions only to find out the customer stated that she is a sub-contractor for the buyback company. I believe many errors were had here starting with the opening of the account and CIP process. I believe we need to document that the customers is a sub-contractor of the book buying company and review the contract because the money collected belongs to the company not the individual. The individual is paid commission. The funds collected are wired to the company so our customer is not actually owner of the funds.

Any input would be appreciated.

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#1816013 - 05/21/13 09:49 AM Re: Book Buyback Sub-Contractor 2old2care
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,948
Galveston, TX
Customer deposits cash and then withdraws cash.

Sounds like he owned the cash to me.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1878973 - 12/16/13 07:21 PM Re: Book Buyback Sub-Contractor 2old2care
Rangers Fan Offline
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Joined: Dec 2001
Posts: 345
We have an unusual but related one but in this case, the account was an individual account (no reference to being a sub-contractor), funds are credited ACH from a book buyback company and the individual then cashes large checks (6 digits) to pay out for the books sold back to them. I have concerns and apparently there was no contract on file from the company but I am not sure it was fully disclosed what they would be doing. They try to make the check payable to the business but the business folks are nowhere involved in the transaction. My concern is the documentation being incorrect at account opening(should not be a consumer account), is there skimming going on? Who knows what is being remitted or paid and this should not be my concern, just looks odd.

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#1878980 - 12/16/13 07:25 PM Re: Book Buyback Sub-Contractor 2old2care
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,948
Galveston, TX
Anytime you have a customer doing something you do not fully understand you are entitled to a full explanation or the customer is fully welcome to move their account down the street.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1878993 - 12/16/13 07:35 PM Re: Book Buyback Sub-Contractor 2old2care
2old2care Offline
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Joined: Oct 2006
Posts: 710
PA
I did follow-up after asking the question posted above and there is no contract with the "book buy-back program." They are considered independent contractors with this particular company. Other companies (more well know) do have contracts and that company is listed on the account with the person handling the book sales as an employee.

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