So we have a business who has signed a waiver of liability whereas they have asked that their foremen be allowed to come in with several payroll checks (one for themselves and several for several other employees of the business). We agreed (a few years ago) to do this for this one company and I have run into an issue.

If a foreman comes into the bank and cashes multiple checks, I found out that the tellers are completing a CTR as needed but only listing the foreman as the beneficiary and not the multiple individuals for whom he is cashing a check.

Am I correct that they ALL have to be beneficiaries since we have knowledge that there are multiple payees?

Frankly, I don't like this agreement despite our legal area approving it so I am going to put a stop to it.

Thanks.

It is similar to a situation where the same individual came into the bank with cash and deposited the cash into multiple accounts, so yes you would include the other individuals involved.

As you stated, this is a case where the question that should have been asked, "Should we do this activity?" and not the typical "Can we do this activity?"

Good luck

Exactly - thank you!

Previous thread

As described there, this is a lousy, foolish banking practice. How to fill out the CTR is the lesser portion of your analysis.

Would we still have to list all payees if the foreman receiving the cash had endorsed after them? If this were the case, at our bank, we would only list the foreman as beneficiary on the CTR.

Interesting. We have a business owner that endorses their employees' checks, cashes them, and we list the owner/endorser as beneficiary. It has been our understanding we have no proof the endorser to whom we give the cash to will actually give the cash (although it is assumed they will) to the payees. Our only proof is the cash is going to the endorser conducting the transaction. Through audits and exams we have not been criticized.

I love hanging my hat on the "not been criticized" theory.

If you're counting out the cash for each individual check amount, you won't be able to sell that can of worms to any savvy examiner. As noted, it's a lousy banking practice. I'd be getting my bank's sales folks together and finding a way to get the employer on direct deposit.