Below is an example of an alert I got for a used car lot. My question to the group is...do you consistently require your used car lots to provide documentation of their sales to support cash deposits if they alert for structuring? Because we have a lot of them and the pattern I'm providing here is representative. Could he be structuring--absolutely. Could he have sold 5 cars this month? Absolutely. Or..do others apply some additional criteria to help them decide short of confronting the customer? For example, all made at the same branch (these were). Our structuring alerts are monthly and I swear every one of these lots seems to alert.

9/28 $5,500.00
9/30 $5,300.00
10/6 $3,400.00
10/16 $7,000.00
10/20 $7,800.00

I had several of these accounts and the amounts are consistent with the industry. My customers had websites that showed these prices and that is what I used as supporting documentation. Have you tried looking at their website for the pricing?

That's a great idea. It's absolutely possible for this to be totally up and up.

Only a personal opinion: there's nothing in that history that suggests structuring to me.

No, I agree, the question is what to write on those pesky alert comments to support our decision.

"Deposit pattern consistent with anticipated business activities of the business."

Thank you John. I thought the examiners were giving some banks a hard time about constantly commenting 'Normal activity for this business/customer'. Not the same thing, essentially?

I think that where examiners have had a problem with that phrase is when the examiners feel that the bank isn't really paying attention to the account to see if maybe there's something ABnormal hitting the account, along with the "normal" activity. In other words, they get nervous if it seems like bank staff are rubber stamping the exception reports without checking things out.

Use of that "excuse" language can also get excessive if a bank's alarms are too sensitive, so that too many false alarms are set off. That tends to hide the truly suspect activity.

"See supporting documentation in customer file" adds weight to the phrase "consistent with the LOB". We did get written up for that type of comment and have now added a phrase like the one just mentioned and they were happy with it.

I think the most important thing you need to do is adjust the settings that generate an alert in this situation.

Ken, help me understand. In order to avoid a structuring alert on the above scenario, I would have to exclude deposits of over $7,000.00. Even if I excluded all 3 of the small transactions, the (2) 7K items would have triggered the alert. So, are you saying on a used car lot it might pass muster with the examiners to INCLUDE only deposits of say...8K and up?

I would not change my parameters. It just might one of those customers on which you have to review on a consistent basis.

Not Ken but some monitoring systems allow you to make account level exemptions for scenarios. So if you're comfortable that Customer A is who they say they are and you believe that cash activity within certain thresholds is not suspicious for Customer A, you can exempt Customer A from a scenario, thus no alert for Customer A for that scenario. However, the rest of your customer base is still subject the scenario and established parameters.

I would not be comfortable exempting anyone from a structuring alert unless they are CTR exempt--which of course a car lot never can be. I agree with rlcarey I think. We are stuck with the used car lots. I don't see anyway to change the parameters on the scenario to make this easier that would be defensible in an exam.

I agree with you Daisy. If you set the parameters or even set it where that account won't hit the alert, I think the Examiners would have an issue with that as well. For the car dealers, fast food restaurants and others that hit every month, I just continue to say the same thing every month, "normal activity for this customer". It is very time consumming and unfortunately I haven't been able to come up with a faster method to it.