Hi -
Scenario I'd like to run by... We have many business customers that make multiple deposits over the weekend (Saturday and Monday - all on Monday's business date). The deposits each time are less than $10,000 - but total more than $10k when you add them all up. In most cases they would go to different tellers. Are we required to track the conductors on the smaller deposits since at the time we didn't know there would be over 10K? Or since none individually are over $10k can we use the Multiple Deposits reason why conductor information is missing? Someone told us that since it is the customer's usual activity to come in every Saturday and every Monday we 'have knowledge' there could be a reportable transaction so we have to monitor and track them. We ARE catching the deposits and filing behind the scenes.... Thanks.

It's not going to be the answer you were hoping for, but yes, you must put forth some documented effort to identify all of the persons who conducted the transactions.

Click here and scroll down to Administrative Ruling 92-2. You will find phrases indicating the bank:

“...is encouraged to make a reasonable effort to provide the information called for...Such efforts could include a search of the institution’s records or a phone call...to identify the persons that conducted the transactions.

Administrative rulings have force of law. This one may be dated, but it has never been repealed and the underlying rationale offered for the conclusions it draws are still relevant.

That's what I was afraid of.
Thank you.