"Wells Fargo & Co. and Bank of America Corp. are planning to implement policies that would ban people from depositing cash into other customers' accounts, the San Francisco Business Times reported Nov. 28.

The move is part of their effort to strengthen security, spokespersons from both companies told the publication.

Bank of America plans to adopt the rule in December, while Wells Fargo will conduct a roll-out phase through early 2018, the news outlet wrote.

The Business Times also added that the new policies suggest another move to motivate customers to use digital banking services, which are much cheaper for the companies."

^^^ came through a news feed we get daily. My boss and I discussed it this morning and are debating whether to implement at our banks. Any banks already doing this? If so, how is it being received by your customers and how are you preventing it?

Your story.

Chase revised theirs in 2014. It's intended to eliminate funneling which is possible when a bank with a large geographic footprint has a criminal customer with mules in a widespread area; i.e. not every bank needs such a mechanism.

Your need for it would be demonstrated by filing multiple CTRs with the "aggregated transactions" box checked; i.e. your customer is generating CTRs, but you don't know who made the deposits.

Thanks, Ken!

We do not do that because, as Ken pointed out, we are still small enough where this is not an issue.

Unless you have a large geographic footprint or are a credit union with a large shared branching network it's probably not an issue. I would think that most institutions would be able to pick up on this activity with their monitoring tools and procedures as Ken mentioned.

Some banks discourage this type of activity by collecting all the information for a CTR for conductors over a certain threshold. Some teller systems allow for this. We did it at a bank I worked for in the past. If the conductor is a mule, they don't want to give their name.

A banker sent me a customer brochure from U.S. Bank that indicates all individuals conducting cash transactions regardless of amount must provide identification. The brochure contained a statement which is repeated in a longer FAQ on the bank's website.

Do all banks have this requirement? Yes, all banks are required to comply with regulatory guidelines for cash reporting.

I won't bother to critique the incredibly obvious...

somewhere in the deep darker corner office is a US Bank employee who has convinced management this is a wise move...can't wait for the negative repercussions to start...

but it's just a little lie.........(end sarcasm font)

well, this is 100% truthful - all banks are required to comply with regulatory guidelines for cash reporting

however, they lead you to believe that their process is in compliance, which it is not...

This is something that is being forced upon banks by examiners, I know of a couple of banks that have caved and started collecting ID from anyone making a cash deposit in response to criticism from regulators. From what I've heard, it's usually a concession that is made as a part of a larger issue with other BSA/AML problems. The bank gets in hot water over BSA and as a part of their plan to dig themselves out, they agree to this. Soon it will be considered "Best Practice".

Our teller system requires the conductor id before allowing cash to be taken out or brought in. It's not a big deal and does help with reporting.

Most of these small things are not a big deal like Susielou states. The problem is that there is a never ending supply of small things that keep getting crammed down our throats.

This "regulatory creep" has taken longer than I thought it would. An examiner who recommends getting ID on all cash transactions, without regard to the bank's geographic footprint or the number of CTRs with the "aggregated" box checked, is engaging in a public demonstration of ignorance.

"Risk based" means the exact opposite of treating all customers as high risk.

I think most have already caved into the process of gathering ID information at a threshold well below $10k under repeated regulatory pressure. Setting a threshold of $2,500-$3,000 seems pretty common; although, if there are any issues at all within the BSA program that require some sort of formal attention the amount always seems to drop to a ridiculously low figure. I'm not saying it's right, just an observation.

I think this probably originated when automated monitoring and cash aggregation reports were not as common as they are today and some forms of micro-structuring were probably going undetected. I remember having to implement a process for having tellers enter transactor and beneficiary information on a spreadsheet for all cash transactions over $3,000 and then having to combine the entries and manually filter/aggregating the entries. Front line and back office automation have come a long way since then.

Since August, BB&T has only allowed cash deposits to personal accounts by an owner or an authorized signer. Their lobby brochure indicates clients (?) may be asked to provide identification.