In terms of SAR filing, if the subject of your SAR is someone who's only relationship with your bank is that they lease a safe deposit box, is that a customer? Or would it be something else? For SAR reporting would you list them as an "other" and Safe Deposit Box Leasee?

How bout in non-SAR related terms. Would you treat that safe deposit box leaser as a non customer? In my opinion, the do not have an account relationship with the bank and therefore are a non customer.

According to CIP, a safe deposit box is considered an account. I don't see how you could reasonably say that someone who leases a safe deposit box wouldn't be considered a customer.


https://www.ffiec.gov/bsa_aml_infobase/pages_manual/OLM_011.htm

Pursuant to the CIP rule, an "account" is a formal banking relationship to provide or engage in services, dealings, or other financial transactions, and includes a deposit account, a transaction or asset account, a credit account, or another extension of credit. An account also includes a relationship established to provide a safe deposit box or other safekeeping services or to provide cash management, custodian, or trust services.

I agree they are customers. We do not permit this situation. All fees for SDB's must be debited from a DDA account at our bank. Saves me some grief.

Thank you for the information. I just can't wrap my head around the fact that its not a transaction account therefore not an account. But I think your reasoning has definitely set my head straight. In my opinion, we should not permit this either.

No thinking required: The language Justin provided isn't in quotes, but it's taken from the CIP regulation; a safe deposit box is an "account."