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#2006679 - 04/07/15 09:32 PM Exchange currancy for non-customer
t0dd Offline
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Is there something within BSA that says we should not exchange currency for a non-customer. We have a few non-customers who on occasion come in with a $20 bill and want us to exchange if for 2 $10's or a $10 and 2 - $5's. We have recently implemented a policy that says we won't conduct any activity for non-customers. Seems a little extreme to me however I just want to get someone else's take.

Thank you in advance for your response.

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#2006680 - 04/07/15 09:39 PM Re: Exchange currancy for non-customer t0dd
Sunshine Lady Offline
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I have not seen anything in the BSA policy that would prohibit the bank from exchanging for non-customers. I think it is what your bank policy is. If your policy says that you won't conduct business for non-customers, then it is hard to then say, but we will exchange currency for you. If you were to get a counterfeit bill, you do not have a recourse account.
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#2006681 - 04/07/15 09:42 PM Re: Exchange currancy for non-customer t0dd
ACBbank Offline
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This is a Bank's decision to make. Most banks I know won't conduct any non-customer transactions.
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#2006684 - 04/07/15 09:45 PM Re: Exchange currancy for non-customer t0dd
Doug Hendrickson Offline
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I don't recall seeing anything in the BSA related to the topic. Certainly there are extra 'hoops' you have to go through for non-customers if they are engaging in transactions which are subject to recordkeeping requirements.

However, unless their currency exchanges become questionnable in some way, which doesn't sound like the scenario you described, I don't see any reason not to conduct the transaction.

Is there really a concern with BSA, such that your bank doesn't want to take any risk with a non-customer, or does your bank just not want to expend the effort for someone who doesn't bank with you and therefore provides no income or source of funds?
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#2006685 - 04/07/15 09:48 PM Re: Exchange currancy for non-customer t0dd
Princess Romeo Offline

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Send 'em to First Citywide - Your Change Bank
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#2006697 - 04/08/15 12:39 AM Re: Exchange currancy for non-customer Princess Romeo
Doug Hendrickson Offline
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Thank you for the laugh of the day!!!!!!!!!!!!
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#2006719 - 04/08/15 01:16 PM Re: Exchange currancy for non-customer Doug Hendrickson
ACBbank Offline
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Originally Posted By Doug Hendrickson

Is there really a concern with BSA, such that your bank doesn't want to take any risk with a non-customer, or does your bank just not want to expend the effort for someone who doesn't bank with you and therefore provides no income or source of funds?


That's the main reason Doug. But there are people out there who will also attempt to exchange counterfeit currency at a Bank. Since they are non-customer, we typically have no recourse. It's simply not worth it.
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#2006722 - 04/08/15 01:21 PM Re: Exchange currancy for non-customer t0dd
edAudit Offline
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Originally Posted By t0dd
Is there something within BSA that says we should not exchange currency for a non-customer. We have a few non-customers who on occasion come in with a $20 bill and want us to exchange if for 2 $10's or a $10 and 2 - $5's. We have recently implemented a policy that says we won't conduct any activity for non-customers. Seems a little extreme to me however I just want to get someone else's take.

Thank you in advance for your response.



There also the non-customer that requests and receives for the 20, 2 tens and a five.


Small amounts sure.

Anything that has BSA written on it point them to the door
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#2006735 - 04/08/15 01:37 PM Re: Exchange currancy for non-customer t0dd
CompliantOkie Offline
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I agree with ed. Set a threshhold you will exchange and stick to it.

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#2006741 - 04/08/15 01:45 PM Re: Exchange currancy for non-customer CompliantOkie
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Originally Posted By CompliantOkie
I agree with ed. Set a threshhold you will exchange and stick to it.


^^This.
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#2006918 - 04/08/15 09:02 PM Re: Exchange currancy for non-customer t0dd
devsfan Offline
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Joined: Jun 2004
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NYC
I once needed change for a parking meter and went into a (major) bank right by the parking spot to break a $1 bill and they would not do it since I was not a customer. That was frustrating to me and I fail to see the BSA implication for them for a small transaction like this.

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#2007004 - 04/09/15 01:21 PM Re: Exchange currancy for non-customer t0dd
John Burnett Offline
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The huge increase in regulatory burden from all directions has made banks develop policies and procedures (P&Ps), many of which they never had before. In some cases, examiners push for P&Ps where there's no legal or regulatory mandate for them. It may have driven some banks to use P&P as substitutes for common sense, which is what helps must mortals make decisions where there are no P&Ps.

So we have P&Ps with black and white edicts where common sense used to allow for dealing with gray areas. If a bank adopts a policy that it won't make change for any amount for non-customers, there's no longer a need to waste time explaining to a teller the difference between an individual asking for change to feed a parking meter and a non-customer business asking to swap $15,000 in large bills for $15,000 in small bills.

Complexity is driving common sense out.
Last edited by John Burnett; 04/09/15 01:23 PM.
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#2007024 - 04/09/15 02:00 PM Re: Exchange currancy for non-customer t0dd
Tom Owen Offline
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Joined: Nov 2014
Posts: 43
PA
We charge 5% fee for non customers and further controls for higher limits. Usually deters the exchange, nobody wants to be charged a buck to break up a twenty. We try to use the underlying theme that we are providing a service and we are not required to exchange anything for a non-customer.
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#2007420 - 04/10/15 04:42 PM Re: Exchange currancy for non-customer t0dd
Elwood P. Dowd Offline
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Banks that refuse to break a $20 for a non customer are not doing it for BSA purposes any more than a bank refusing to verify funds on a check is doing it for privacy purposes. They are refusing because they simply don't want to do it; the law which hardly applies is the excuse, not the reason for the policy.

A request to exchange small bills for large ($100) is considered to be an emblem of drug trafficking. A request to break a $20 or a $10 is an emblem of a guy who needs cash for the parking meter...
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#2007453 - 04/10/15 05:41 PM Re: Exchange currancy for non-customer t0dd
Princess Romeo Offline

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It's a management decision that should weigh the costs and benefits of providing small exchange services for non-customers.

Your risks are:
1. Potential for counterfeit bills with no recourse.
2. Potential BSA issue if non-customer manages to "structure" currency exchanges.
3. Non-customer will be diverting time and resources from customers - i.e. customer needs to wait longer in line because non-customer is assisted.

Mitigation for those risks:
1. Limit non-customer exchange to $20 and have counterfeit detector for tellers (they should have those anyways since you're going to battle your customer if you say, after the fact, the bills tendered were counterfeit.)

Potential benefit:
Have tellers give non-customer a friendly smile and a marketing piece with "intro" special to open an account at the bank.

Or put it this way - if I'm not all that happy with my current bank, and I need change to pay the meter or other small cash item, and I get a friendly smile, the change I need, and a "boost" for opening an account, I may just have found a new bank.


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CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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#2007521 - 04/10/15 07:38 PM Re: Exchange currancy for non-customer t0dd
LiveFromNYC Offline
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My Bank decided to stop offering non-customer services because we felt these type of transaction are covered by OFAC regulations. And as we prefer not to expend resources on screening and the inevitable vetting of FALSE matches, we decided to cease offering.

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