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#2096579 - 09/01/16 04:10 PM ID for CTR transactor?
Rancher Offline
Member
Joined: Nov 2006
Posts: 75
The owner of a business sent their son to do a cash withdrawal for the business that is CTR reportable. The son has no relationships with us so we collected all of his identifying info during the transaction except an ID. His drivers license is suspended so he does not have it, and he has no other state issued ID, passport, government issued ID, etc. Is there anything else we can use for an ID on the CTR?

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#2096584 - 09/01/16 04:16 PM Re: ID for CTR transactor? Rancher
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,796
You are here
Identification Requirements. All individuals (except
employees of armored car services) conducting a
reportable transaction(s) for themselves or for another
person, must be identified by means of an official
document(s). Acceptable forms of identification include
a driver’s license, military and military/dependent
identification cards, passport, state issued identification
card, cedular card (foreign), non-resident alien
identification cards, or any other identification document
or documents, which contain name and preferably
address and a photograph and are normally acceptable
by financial institutions as a means of identification when
cashing checks for persons other than established
customers.
Acceptable identification information obtained
previously and maintained in the financial institution’s
records may be used. For example, if documents
verifying an individual’s identity were examined and
recorded on a signature card when an account was
opened, the financial institution may rely on that
information. In completing the CTR, the financial
institution must indicate on the form the method, type,
and number of the identification. Statements such as
“known customer” or “signature card on file” are not
sufficient for form completion.
http://www.occ.gov/news-issuances/bulletins/2003/OCC2003-48a.pdf
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#2096629 - 09/01/16 06:08 PM Re: ID for CTR transactor? Rancher
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
I would refuse the deposit and tell them to send someone with an ID.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2096711 - 09/01/16 08:57 PM Re: ID for CTR transactor? Rancher
Bankwoman1 Offline
Diamond Poster
Joined: Dec 2015
Posts: 1,046
Midwest
I'm surprised a cash withdraw of that amount was allowed by someone with no relationship to the bank - and the account he was withdrawing from especially. Particularly since he had no valid ID at the time of the withdraw. I know this has nothing to do with your question - I'm just curious if I'm the only person who finds this strange that the transaction was allowed?

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#2096735 - 09/02/16 11:35 AM Re: ID for CTR transactor? Rancher
thomasj Offline
Power Poster
Joined: Mar 2001
Posts: 5,063
Pennsylvania
I think we'd all like to say that wouldn't happen in our bank, but we can all think of some pretty realistic scenarios where this could happen. Business is a good customer, the son brings in deposits every day, everyone knows him, blah, blah, blah. I can tell you, we've been in this scenario a few times, more often with deposits than withdrawals, but it is an uncomfortable position to be in. I would have the branch manager contact the customer and explain the situation and go over all of the acceptable documents you will accept for identification and have the transactor bring in whatever they have.

After that, I would do some training specific to identifying conductors of large cash transactions. I always tell the front line that it's easier to get identifying information before you process the transaction than after. I would document all of the actions taken, including the training in case it happens to be one of those nuggets that surfaces during an exam or audit.
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