At compliance meeting today it was brought up the former BSA Officer had stated you could not do a 'telepost' for transfers if the ownership was not matched on both accounts. For instance, if John calls in and wants to transfer funds via phone request to Mary, but John is not on Mary's account. Instead of doing a 'telepost' thru the teller system, you must create tickets. However, this could potentially affect the number of transactions per Reg D. My question for BSA.....is this in any way BSA related?

I will post this on the Operations forum also in regards to any compliance issues.

This is more of an operational question. I guess you could make an argument that the transfer request was fraudulent, but that's a different discussion.

ACBbank, you are correct. I just wanted to make sure it was in no way BSA related. For some reason the former BSA Officers guidance was dictating it and no one seems to know why.

I was under the impression that the Reg D transaction limits have been indefinitely suspended. Am I wrong?

No, you're correct RockChucker.

Thank you for your feedback!

This has a connection to BSA regs because of the recordkeeping requirements for funds transfers. When ownership between the accounts for an intrabank transfer is not identical, the recordkeeping requirement will apply to transfers of $3,000 or more. SEE 31 CFR § 1020.410(a).

There also may be a disclosure issue on your periodic statement if not set up properly with your CORE.