We're beginning to offer a "Smart Safe" cash management product, which I'm sure most are familiar with, (customer has electronic safe located at business, deposits cash to safe, provisional credit given to customer by the Bank daily for the amount deposited, and armored car empties on weekly basis).

We've heard differing opinions on when to file CTRs for these transactions, some have said you file based on the daily amount deposited to the safe and reported to the Bank, or on the "bulk" amount retrieved by the armored car service periodically.

Does anyone who offers this product have some insight?

I've worked at institutions that offer the product. They have set up cash aggregation based on the date the cash is fed into the smart safe.

It goes without saying that these need to be added to whatever cash might also happen to cross the teller line for the customer on the day (if there is any) for the purpose of aggregation.

This is as close to: "Which came first, the chicken or the egg?" as you can get with BSA.

The customer reports $4,000 in cash Monday through Thursday. If you report on the customer's business day, no CTR. Yet the armored car delivers $16,000 in cash on Friday and it goes unreported? I would do the calculation on the bank's business day, not the customer's.

Yet, I would be uncomfortable not aggregating Tuesday's $4,000 cash deposit with a $7,000 loan payment or a currency exchange. However, I think it highly unlikely that a customer using this mechanism would have other cash transactions - it simply would not make sense.

Any vendor peddling this product/service, should ask FinCEN for an administrative ruling so they could tell their clients what to do with some assurance...

P.S. I assume any bank that would go along with this would require the customer to maintain a pledged account for the maximum possible amount of credit for as yet undelivered cash.

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Thanks to both!

We were heading down the road of "bank's business day" as the filing trigger.