There is a brochure on structuring that some banks choose to give out to customers.
I don't remember the exact name of it.
Maybe someone else can provide it here.
A lot of banks prefer not to do this, as it would trigger a conversation that could put the bank employee in a situation where they could be accused of assisting the customer in structuring.
It's a touchy subject.

We have the brochure. It's called "Facts you Should Know". But I'm looking for more. I believe this customer just doesn't understand the CTR process. We may have a language barrier.

That is the brochure, and it is the only one I know of.
I could not help you with scripting, as we do not allow our staff to get into those conversations, and I personally agree with our stand on it.
Maybe someone else will give you another slant on this topic.
Good luck.

I concur with MC on this one. Hand them the brochure and let that be that. If you have a conversation and their patterns change - like closing the account and then spreading the deposits among multiple institutions - you just helped them in further structuring their transactions.

Yeah, I agree with Randy and MC. I would avoid having staff discuss any suspicious activity with your customers. Last thing you want is a teller saying something they shouldnt.

The brochure seems like a good idea.

We have several long time customers that regularly structure their transactions like this. We have been filing SARs for several years over and over. Bank Management will not close these accounts because these are long standing business customers well known in the community. I have brought this topic up at more than on FDIC/FINCEN BSA seminars and FINCEN has said that it might be prudent to have a discussion with the customer as newbsa is suggesting. FINCEN suggested that a conversation with the owner about the activity of depositing just under the reporting threshold was looking suspicious to the bank. There should be no mention of reporting that suspicious activity of course.

I have not been able to bring myself to go there because I agree with the other posters, that this will just open up further discussion.

There can be legitimate reasons for depositing just under the threshold and we have in the past asked customers why they only deposit XXX amount each time. We don't say the activity is suspicious or 'under the CTR reporting requirement', just a simple question. We have been told by customers that some insurance/bonding policies will only cover under $10,000 when transporting cash to/from the bank. Some customers, even if the insurance/bonding policy does cover them, say they are not comfortable transporting large amounts of currency at one time, so they'll make several trips a day with small amounts of currency. I guess it all goes back to 'knowing your customers' and their individual types of activity as well as their individual risk tolerance. If I can document a legitimate reason for not filing, I won't file a structuring SAR, especially if I see nothing else suspicious on the account.

If your customer is telling you that his insurance or bonding company won't cover amounts of $10,000 or more, it would be prudent to verify that fact with the insuror. With internet access, your business owner could have concocted the excuse based on discussions just like the one we are currently engaged in.

Prior thread.

Where can I get this "Facts You Should Know" brochure? Searches here at BOL and at FinCEN don't turn up anything.

Click Here

National Association for Bank Security: http://www.banksecurity.com/

Thanks!

We have contacted to FinCen and ask him about "Facts You Should Know" brochure. Seriously, he doesn't like it! What do you think?

You will, of course, get different opinions on the worth of that or any other brochure designed for the same purpose. That particular brochure has been available for years (I should probably say decades) and I have not heard of any bank getting dinged for using it.

Strict adherence to a policy of handing out this or a similar brochure and not providing any other information in response to an inquiry from a customer about CTR filing will guarantee one thing-- that loose tongues won't get you in trouble, and you will be providing uniform information to anyone who asks.

The "Facts You Should Know" was originally marketed by a different organization, the American Bankers Association. Handing it to someone reflects nothing more that the fact that we all live in a country where people are entitled to know the law.

It's ironic that anyone affiliated with Treasury would express reservations about handing out information about the reporting requirement - several years ago Treasury issued a notice of proposed rulemaking to the effect that banks would be required to hand out a similar notice whenever anyone deposited $3,000 or more in currency. That's when and where the ABA got the idea for this publication.