OK all you CTR experts out there...

If you have a contracted courier service that picks up deposits from a business and drops them off at the bank, and the cash is over the CTR reporting limit;

In section B of the CTR do you check 'Armored Car Service' as the conductor, or do you check 'Mail Deposit or Shipment'.??

In the grand scheme of things I really don't think it matters which, but this has been an ongoing debate and I'd like to solve it once and for all.

Who contracted for the pickup - the customer or the bank?

Is this an armored car company or a contracted courier service?

It's a service the bank provides to our customers. We are a one-branch bank so we provide courier service to our clients to pick up their deposits at their place of business. It is a contracted courier service, not an actual armored vehicle such as Loomis or Garda.

So, you are operating a mobile branch. The conductor of the transaction is whoever is handing them the deposit when they go to pick it up.

Thank you rlCarey. Can you point me to more information/Reg regarding a 'mobile branch'?

Randy, I'd like to follow up to see if my understanding of when a "mobile branch" is required, in connection with picking up deposits, is correct:

FI contracted Armored Car Service (ACS): no mobile branch
Customer contracted ACS: no mobile branch
Customer contracted courier service: no mobile branch
FI contracted courier service: mobile branch

We have only recently started to use an ACS, contracted by our customer(s), and I wanted to be sure that we didn't need anything else.

Thanks, Doug

Doug - If you are contracting the ACS, it may very well still be considered a mobile branch, but you would have to look at the specific branching regulations that apply to your institution.

This is why all of these services are usually contracted by the customers.

For example, if you are a National Bank:

A messenger service is any service used by a national bank and its customers, to pick up from, and deliver to, specific customers at locations, such as homes or offices, items involving branching transactions — that is, items constituting deposits, withdrawals, or payments of loan proceeds — between the bank and its customers. (12 CFR 7.1012(a)).

Many thanks!

National banks should go here:

http://www.occ.gov/publications/publications-by-type/licensing-manuals/branches.pdf

State banks would have to consult State law and here:

https://www.fdic.gov/regulations/laws/rules/2000-500.html

I misspoke regarding the courier service.

We are contracted with a non-affiliated third party to pick up deposits on behalf of our customers. We, the bank, assume all liability for insurance purposes.

In this scenario, who should we consider the conductor? a) Armored Car Service, b) Mail Deposit or Shipment, or as you pointed out previously, the person picking up the deposit?

Thanks again for all your help, I know we're making this more difficult than it needs to be.

If you are paying them, they are acting as your agent. Them receiving the deposit is the same as the customer walking into the branch.

Whether you are paying a third-party to do it for you or operating the courier service yourself, doesn't really make a difference.

So its safe to say the transactor is the individual who gives the currency to or receives the currency from the Bank's agent.

An individual conducting a transaction with the agent of the Bank is considered to be conducting a transaction directly with the Bank.

And that is one reason why not too many banks operate a mobile branch through courier services.

.....because we don't know which individual(conductor) at the place of business gave the deposit to the courier (Bank Agent)....unless the courier is obtaining that information on behalf of the Bank...

OK, I think I got it.....thank you rlcarey!!