Recently the pastor of a not for profit church has begun taking cash out of the churches account. Suspicious yes, but here is the issue, the pastor never uses the church's checks, she uses our in-house DDA withdrawal and makes it out to cash. Should the check be made out to her versus cash? This pastor is very demanding and will even make the staff fill the DDA withdrawal slip out so all she has to do is sign the withdrawal slip. Am I being over zealous to make the pastor make and complete the withdrawal slip herself? I'm just very concerned but I'm not sure how or why I can reasonably explain the change to her. Thank you.

What does you check cashing policy state? If you don't have it in your policy it is hard to enforce something on one customer but not on others.

A demanding pastor?!?! Say it ain't so!

I don't perceive any BSA implications so I'm not certain why this is in this forum, but strip away the facts regarding church, pastor, etc. when you are looking for an answer. If this person is an authorized signer on the account, then her status as a customer or a customer's authorized signer is the same as the guy who runs the filling station.

Your employees should not be filling out checks, deposit slips, anything on behalf of your customers who do not have some sort of physical impairment that would prevent them from doing it themselves.

Ken, I presume the BSA implications are that the bank is concerned the pastor is using the cash for personal gain rather than furthering the ministry of parish. It doesn't matter whether or not the instrument used to withdraw cash is payable to cash or to an individual, the result is the same. As with any investigation, your options are to ask the pastor directly or contact another account signer to make sure they are aware of the activity.

One plausible explanation is that the pastor maintains a discretionary fund to assist individuals who approach the church requesting help to pay rent, utilities, buy groceries, medicine, etc. The OP doesn't specify how much cash we are talking about so obviously the amount/frequency would also be a factor in the investigation.

I kinda wondered about that, but using a counter check vs. a pre-printed check isn't going to disguise her actions in any way. It might allow her to avoid going to the "keeper of the checks" and discussing her withdrawals in advance...just as it would the guy at the filling station.

The pastor has told the staff that she and her church members feel the banking industry is on the verge of economic disaster so they are withdrawing money to stockpile and to purchase supplies for the end. Seriously, the amount over the last few months is over $10,000. We are in a RURAL community of about 300 people and yes for our area, this is suspicious and as the BSA officer I'm concerned about the parish, the community and repercussions on the bank.

If you don't ask the pastor about this withdrawal pattern you won't have any chance of finding out what's going on. If it's suspicious, by all means start working on a SAR.

"and to purchase supplies for the end"

My concern would be for the members of the church first. SAR second.

This pastor is very demanding and will even make the staff fill the DDA withdrawal slip out so all she has to do is sign the withdrawal slip.

When I started in banking in the past we had several of theses but would not longer tolerate this type of behavior. (customer have made statements that the amounts were incorrect)

As John has stated you need to find out from the customer what is going on.

She is stockpiling for the end. That is what she has told the staff. I have no reason to doubt what the staff has told me. Thank you for your input but as I said, we are a small rural community and whatever I do will be placed under the communities microscope so I must tread very carefully.

Being in the "small rural community" must be difficult in this case best of luck.

Thank you. I appreciate all the responses.

The issue seems to have morphed from the implications of using a counter check vs. a pre-printed check to the purpose of the cash withdrawals. If this group had some "survivalist" bent and is stockpiling supplies for "the end," they wouldn't need cash to purchase them; i.e. checks and credit cards would work just fine. Perhaps they really don't understand the implications of their own theory and they are actually stockpiling cash.

You could ask the pastor, but you indicate she's already answered the question. Your query would be better directed to the organization's financial officer or at least another signatory on the account. There will be a reaction. Better that one than the one that will occur when the flock becomes aware of the withdrawals and you are forced to admit that you thought something was amiss months before.

P.S. If you think they are stockpiling cash or materials in anticipation of some economic cataclysm, you do not have the basis for a SAR. Neither activity is illegal and the latter makes a nice hobby for lots of people. If you think the pastor may be embezzling funds you are good to go, but, as mentioned earlier, putting a stop to the activity is more important than filing the SAR.