Scenario: We have a customer who appears to work for a different financial institution. The customer gets ACH deposits to their account with us from their employing bank, but it's unknown if they have an account relationship with that bank. The customer has had structured cash deposits with us, and we would like to 314(b) their employing bank. Can we do that on the basis of knowing our customer is their employee? I have not had a situation like this before, where our customer was not a known customer of the bank we would be inquiring to.

FYI I finally got a response from Fincen and they said that yes, we can communicate with the other bank in that situation.

Thank you for updating us Susan. I wish I had the knowledge to comment earlier but I appreciate you telling us the outcome.