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#2249600 - 02/23/21 06:22 PM CTR Help- bank messenger/courier
Anonymous
Unregistered

If a customer asks for a CTR reportable amount of cash to be prepared for pick up, but is not able to come before closing so a bank officer takes them the cash, how do we fill out the CTR?

I found conflicting information that
1. If an employee takes the cash to the customer, acting on their own behalf, then the employee would be the conductor and the customer is the person on who's behalf the transaction was completed.
2. If the employee acted on behalf of the bank it could be considered a messenger/mobile branch depending on our state. (is this true if it is a single occurrence?)

I have read previous threads and am still confused because most of them refer to the bank picking up deposits, not taking cash to the customer. And yes, I understand this is poor practice, etc... from all of the other posts.

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#2249604 - 02/23/21 06:39 PM Re: CTR Help- bank messenger/courier Anonymous
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,722
Illinois
1. No, the employee acted as a teller.

2. Sounds like you've read prior threads about insurance bonding, mobile branches, etc. Since it sounds like you don't have a mobile branch license, I would put a stop to this pronto. Regardless, since your employee is the teller, they should have obtained the identifying information from the person they handed the cash to the same as a teller would have at a window in the bank. If you don't have this information, then I suggest you call the customer to obtain it so you can correctly complete your CTR.
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#2249647 - 02/24/21 02:20 AM Re: CTR Help- bank messenger/courier Anonymous
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
When I got to the "bank officer takes (to the customer) the cash" part, I cringed. My greatest concern is your blanket bond, not a CTR filing. How would your insurer handle a claim arising from an incident where the cash went missing? Following closely behind concern #1 is a concern for the safety of the bank officer transporting > $10,000...and the lawsuits an aggrieved family could bring against the bank in the sad event that their loved one is injured or killed by a robber!
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...gone fishing.

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#2249665 - 02/24/21 03:51 PM Re: CTR Help- bank messenger/courier Anonymous
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I won't preach about a poor business and security decision, but I will second those who say you file this CTR as though the individual at the customer end came into the bank and picked up the cash from a teller.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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