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#2270640 - 05/19/22 02:45 PM Closing account due to ongoing structuring
J_G Online
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Joined: Dec 2010
Posts: 220
We have a customer who continues to structure cash transactions. Several $9,000 cash deposits and then they will get a cashier's check. This is pretty much the only thing the account is being used for. We'd like to close the account. What reason should we give the customer? Could it be a potential issue if we say we are closing it due to structuring?

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#2270641 - 05/19/22 02:50 PM Re: Closing account due to ongoing structuring J_G
praBSA Offline
Gold Star
Joined: Aug 2018
Posts: 330
You don't need to give them a reason. If you've provided them a CTR Brochure, they will probably get the hint. Your account agreement should say you can choose the exit the relationship at any time for any reason. You choose who you want to bank.

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#2270809 - 05/24/22 03:24 PM Re: Closing account due to ongoing structuring J_G
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,593
Cape Cod
Giving a customer a reason for the bank's pulling the plug on their account(s) is an invitation for an argument. It can also lead to threats of lawsuits and other nasty stuff. Don't offer a reason. Most terminated customers know why they are getting the boot. And if they are structuring, they may be irked they were discovered, but they will know why they are being exiled.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2271272 - 06/06/22 09:38 PM Re: Closing account due to ongoing structuring J_G
Lindsay Offline
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Joined: Feb 2020
Posts: 9
We often use this general language in the notice of closure.

"The account activity does not match what was originally reported as expected activity.

As stated in your Account Terms and Conditions, “we may close the account at any time upon reasonable notice to you and tender of the account balance personally or by mail."

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#2271275 - 06/07/22 11:27 AM Re: Closing account due to ongoing structuring J_G
rlcarey Online
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Joined: Jul 2001
Posts: 78,958
Galveston, TX
I would totally skip the first sentence. It really is a meaningless statement. Quote your depositor's agreement and be done with it.
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