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#1927176 - 05/28/14 06:38 PM Courier Service
JenW Offline
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Joined: Jan 2014
Posts: 5
I find loads of conversation about Private Courier Service however my question is about what to mark for a Courier who comes into the bank with a deposit who is NOT contracted by the bank who is NOT an Armored Car Service? Should it be 2b with the persons information or 2d with the persons information?

The e-Filing guide would lead me to believe that "If option 2d is selected because a private courier other than an armored car service is involved in the transaction, then the information on the individual agent of that private courier should be recorded in Part I, in accordance with 31 CFR 1010.312." So this means we do not record any courier information ONLY the individual? Just making sure I understand.

Thank You!

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#1927214 - 05/28/14 07:07 PM Re: Courier Service JenW
devsfan Offline
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I am just wondering who would contract with a courier for cash delivery if the courier is not an armored car service. Anyway, for CTR purposes I would check 2d and enter the complete information on the courier company not the courier him/herself.

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#1927253 - 05/28/14 07:53 PM Re: Courier Service devsfan
kw004h Offline
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Chicagoland, IL
I disagree with devsfan - from the instructions already quoted, it states that if the Courier service is a private service other than an armored car service, the individual gets his or her own Part I populated with his or her individual information. The box for "if entity" should not be checked.

Although I do agree that it's a bit batty not to use an armored car service for large amounts of cash, but there it is.....

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#1927257 - 05/28/14 07:59 PM Re: Courier Service JenW
kw004h Offline
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Chicagoland, IL
So to clarify, JenW, if the deposit is brought in by an individual who is working for a private courier service not contracted by the Bank, you check 2d, (don't check "If entity"), and enter the individual's info.

If the deposit is brought in by some individual who is not working for a private courier service (like, the business owner, or a friend, or what have you)you'd check 2b (still not checking "If entity") and enter the individual's info.

You'd only check 2d and "If entity" if the courier is an armored car service, and then you can fill out the rest of the Part I with the armored car company information, not the information of the agent.

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#1927262 - 05/28/14 08:05 PM Re: Courier Service JenW
JenW Offline
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Posts: 5
So would you fill out a second Part 1 on the courier information? That is where I am looking for additional clarification! It is a bit vague, does anyone have a better reference for this.

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#1927291 - 05/28/14 08:35 PM Re: Courier Service JenW
kw004h Offline
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Chicagoland, IL
Correct - you fill out one Part I for the account owner, checking 2c, and one Part I for the individual bringing in the deposit. In this case, your individual bringing in the deposit is working for a private courier, so you select 2d.

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#1927313 - 05/28/14 09:19 PM Re: Courier Service JenW
JenW Offline
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Posts: 5
I should have clarified, I was concerned about filling out an additional Part 1 for the courier information specifically as in ABC Delivery as well as the 2c, and 2d for the individual. So, would I need an additional 2d for ABC Delivery since that is the courier service he/she works for or ONLY the individual is reported on and we mark 2d for that individual.

I am asking because it seems pointless to mark 2d for the individual if we are not going to gather any information on the courier service at all. Why not just mark 2b? Just another one of those FinCEN rules that baffles me is all. Thank you for your help!!

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#1927320 - 05/28/14 09:36 PM Re: Courier Service JenW
kw004h Offline
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Posts: 219
Chicagoland, IL
I see. No, you would not fill out an additional part I for the private courier company in this situation. Only two Part I's are needed.

My understanding is that when a courier company is involved, you report the company's details if and only if it is an armored car service under contract with the customer.
If it is any other type of courier under contract with the customer, you report the information of the individual, and you do not report any infromation about the actual courier company.

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#1927321 - 05/28/14 09:39 PM Re: Courier Service JenW
JenW Offline
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Joined: Jan 2014
Posts: 5
Agreed that is how I understand it as well but I wanted to make sure I wasn't missing anything! Thanks again!

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