So, audit question requesting 3 months of cash shipment logs. We do not maintain any such animal. Each branch has a vault limit and a daily cash reconciliation is signed off by the branch manager and head teller to ensure those limits are maintained. The cash order activity is inputted into Fedline weekly and there is a record of those orders within Fedline but there is no summary and no reporting available from there--we called. All I can hand the auditors is 8 items (cash in and out) per month per branch.

Do others create some sort of manual log internally? How would you ever know it was correct anyway?

Yes, many banks track shipments to / from the branches. It can be interesting to see which branches experience upticks or drop-offs in cash in / out and correlate that to customer activity. It can also lead to some interesting conversations about why that activity is occurring (or has stopped.) Volume / trend analysis is typically what I want to see.

Are you asking about shipping cash internally between branches or shipments to the Fed?
every cash shipment company I have worked with for shipments to Fed (think Brinks armored cars) required the branch to keep a log of shipments with
signatures, dates, amounts and tracking numbers.

I'm talking about ordering cash to and from the Fed. As far as I know, our branches do not routinely transfer cash internally.

I'm very reluctant to recommend we add a manual log process if we have none today and there is no requirement to have logs. It is not clear to me that we (BSA) would actually utilize the logs for purposes of monitoring cash trends, so I would hate to make them do the work for no purpose.

"The cash order activity is inputted into Fedline weekly and there is a record of those orders within Fedline but there is no summary and no reporting available from there-"

Not that keeping a log would be of direct benefit to BSA, but one of my past banking employers did not receive credit from the Fed for a shipment. without the log to verify the shipment was sent, we would have had a difficult time tracking the shipment.

_________________________
What we think, we become.
Buddha

Appreciate the input. That is a good point.

OK let me take a stab at it you have one branch that send out a ton of money and does not file many CTR's. Could an branch employee be assisting a customer money launder?

Just a what if that you may catch with a log (I have heard of a case at a large FI a few years back)

Hmm...if the cash was deposited to a customer's account, our BSA software would catch it, either in a CTR, a structuring or spike alert. If it was not credited to an account, we would have a reconciling item somewhere, I presume.

Now it did cross my mind that they could process currency exchanges outside the account without affecting their vault limits and the cash shipment logs would reflect an increase in activity. It just seems a little far fetched to me. The whole branch would pretty much need to be in on it, wouldn't they?

Maybe I'm not considering all sides here, but do you not have a cash shipment tran code that is or can be used, that way you can track by trancode and you can pull imaged TX cash shipment tickets for back up?

That is an interesting question you raise. Wondering if the Fedline software interfaces at all with our GL or an Internal DDA--seems like it might else how would Finance balance the Fed account? I will inquire.

I imagine that your accounting department does the offset. And that would be reconciled daily by them? Also, if you want a list or history of cash shipments by branch, can't you pull a report from your teller system? Ours we label "cash shipment in" and "cash shipment out".

I'm surprised that this is the first time you heard of this. It is in the standard request list in the Exam Manual on page H-5:

Currency-Shipment Activity

• Make available records reflecting currency shipped to and received from the Federal Reserve Bank or correspondent banks, or reflecting currency shipped between branches and their banks’ central currency vaults for the previous ___________ months. (Examiner to insert a period of time appropriate for the size and complexity of the bank.)

My understanding has always been that it was for the purpose of identifying branches that are net users or accumulators of cash and being able to notice changes in their activity. It's not exactly a sharp edged tool.

It's not that I have never heard of it or that I do not understand the purpose of the audit item. It's just the way the bank has responded to the item in the past has been to hand the auditors a large stack of input orders to Fedline. We have never been criticized for that. But I know it's not what they want, so I was seeking ideas for a better way.

I had not considered that the cash shipments were actually posted in our teller software, but that makes sense too. I will inquire about that as well.

I don't use it for my BSA side, but I use it for my Security Officer role.

I have a simple excel spreadsheet set up, which the head teller fills out and sends back to me monthly, which I then compile.

I've set it up where it will grab the monthly and yearly, totals and averages.

I'd be willing to share it if you want to PM me your info.

In all the years I've been here an auditor has asked for that only once.