If a bank customer is utilizing a licensed MRB Transporter (licensed through the Oklahoma Medical Marijuana Association) would the bank still fill out the CTR with full information on the individual and business using the 2b box of Person conducting transaction for another? It wouldn't fall under the armored car exception where the bank can put "common carrier" and just put the corporate information would it?

I thought a Transporter license authorized them to transport the product and not the money?

Yes, it does. But just wondering if that still qualified as 2d Courier Service? If so, would it fit in with the guidance saying you could put the courier's corporate information rather than the individuals?

Courier? I would not equate them with an Armored Car Service. An individual can have a transport license.

After looking at the FinCEN guidance again and instructions for the common carrier I agree that it would be the individual transporter's information the bank collects.

And I jump back to Randy's initial question and ask why an MRB transporter would be bringing in cash for a deposit to an MRB customer's account. I suppose it's done, even if their license doesn't cover that service. If that is the case, I think you have to treat the warm body that brings in the deposit as any other individual conducting a reportable transaction on behalf of a business.

Thank you. I did see is a webinar note that "if option 2d is selected because a private common courier other than an Armored Car Service is involved, then the information on the individual agent of the private courier should be recorded and that "if entity" should not be checked. So I think that sums up this situation fairly well.