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#678792 - 02/02/07 07:44 PM CTR and Mail Depsosit/Shipment???
Rangers Fan Offline
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This is a new one to me, but I am having a little trouble finding specific clarification on completing a CTR. Have a business customer who called in for a large cash transaction to be prepared for a courier pick up and the teller has marked "b" in Section B for "mail deposit or shipment." This seems like the most obvious choice, but there are also some unusual circumstances that go along with this transaction. It just seems odd to me to be able to use this selection when you have a business entity and cash OUT. We regularly use this one for truly couriered IN deposits and I guess it would work the same for a cash out (I'm thinking change orders for customers and this kind of situation) but this one includes some resistance on the customer's behalf to provide information. It doesn't set well with me that an individual from the business calls in the transaction but of course he is not here to receive the cash and this makes it okay for no one's personal information to be on the CTR? Okay, maybe this is a rant (yes, a SAR is also being considered), but I can't find any additional clarification on if this is an appropriate use of this category in this situation and I have a call into my regulator for additional guidance, but any other FinCEN or other guidance you know of our there that I have missed (nothing in the FFIEC manual), please pass it along. Thanks for suggestions!

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#678813 - 02/02/07 07:52 PM Re: CTR and Mail Depsosit/Shipment??? Rangers Fan
Sing A Little Offline
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I would put the Business in Section A and the courier's information in Section B. JMO
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#678865 - 02/02/07 08:16 PM Re: CTR and Mail Depsosit/Shipment??? Sing A Little
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What if it is the courier service we provide for the company on their other deposit transactions? I guess the fact that he didn't know what was in the locked bag (he never sees what is inside) and he is normally brining us checks and that this category doesn't seem to fit, but it appears to be the closest choice. Ahhhhhhh, I love BSA.....NOT!!!

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#678967 - 02/02/07 08:51 PM Re: CTR and Mail Depsosit/Shipment??? Rangers Fan
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BSA issues are one thing, but if you are using a bank paid courier, it sounds like you are operating a mobile branch and you might want to check on that...

Additionally, what type of an agreement do you have with this business to operate in this fashion. I see it no different than repetitive wire transfers and I would think that before you box up a bunch of cash and ship it to them that you would want adequate authorization security procedures in place.

Delivering this much cash outside of an armored car arrangement is also just asking for big trouble. Techinically, since this is not an armored car service, you should be identifying the courier in Part B.

"Identification Requirements. All individuals (except employees of armored car services) conducting a reportable transaction(s) for themselves or for another person, must be identified by means of an official document(s)."
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#679199 - 02/02/07 10:20 PM Re: CTR and Mail Depsosit/Shipment??? rlcarey
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Richard-Those questions have already been asked and of course I flinched when I heard some of the answers or heard that we were not able to answer those questions right off. Thanks for the input.

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#679410 - 02/05/07 12:52 PM Re: CTR and Mail Depsosit/Shipment??? Rangers Fan
John Burnett Offline
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His name is Randy, for the record.

At the risk of being accused of "piling on," you have a significant problem here.
  • The box for mail deposit or shipment can only be used for cash deposits or shipments that use the U.S. Mail. It's not available as an excuse for missing information in Section B when your bank's courier is involved.
  • Your courier is an agent of the bank. As such, the courier must obtain the identification of the individual to whom the cash is transferred at the customer end of this transaction. The courier doesn't need to know the contents of the bag, but he does need to obtain Section B information before surrendering it.
  • All of the things that Randy has said about branch banking
  • Your use of the "mail shipment" excuse is inappropriate for "couriered in" transactions. If a customer uses an armored car service, use the armored car excuse. But if the bank pays for the service, the armored car excuse doesn't work.
  • You already are thinking SAR. If you don't get full and willing cooperation in filing the Section B entries, I recommend refusing them and filing a SAR.
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#679598 - 02/05/07 03:58 PM Re: CTR and Mail Depsosit/Shipment??? John Burnett
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Ken Golliher and I just finished a webinar on CTR preparation. There will soon be a CD-ROM of the presentation and all our materials available in the BOL Banker Store. Check it out.
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#704088 - 03/21/07 02:46 PM Re: CTR and Mail Depsosit/Shipment??? John Burnett
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John and Randy, my bad on the name.

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#704093 - 03/21/07 02:48 PM Re: CTR and Mail Depsosit/Shipment??? John Burnett
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John and Randy, my bad on the name-please accept my apologies-little stressed when I did the post. Thanks to you both on the input and yes, piling it on is a good fit, but I saw the "pile" coming when I was presented with the information in the first place. You know when we did the clicker sessions at the Top Gun conference and the salary question came up? This is why no matter what we get paid, it is not enough!!

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#705798 - 03/23/07 04:42 PM Re: CTR and Mail Depsosit/Shipment??? Rangers Fan
Jerseygirl Offline
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If a customer is using a bonded courier service to deliver deposits we check the Armored Car block - should we be getting ID on the courier employees?

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#705806 - 03/23/07 04:56 PM Re: CTR and Mail Depsosit/Shipment??? Jerseygirl
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Jerseygirl, We do not require the IDs of the armored courier service employees who bring deposits on behalf of customers. If we would have to enter the ID in Part 2, why would there be a box on the CTR for Armored Car Service?

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#705825 - 03/23/07 05:06 PM Re: CTR and Mail Depsosit/Shipment??? devsfan
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But what if it is a courier service not an armored car?

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#893117 - 01/24/08 07:17 PM Re: CTR and Mail Depsosit/Shipment??? Jerseygirl
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*bump*

I'm not sure if this post answers my question. Can it be re-looked at?

I have bank employees that go out & pick up customer deposits & bring them back to the bank.

What should be listed in Section B?
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#893129 - 01/24/08 07:29 PM Re: CTR and Mail Depsosit/Shipment??? WonderWoman
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That's a mobile branch. Your employee that picks up the deposit should verify the ID of the person who handed them the deposit.

I sure hope your not sending a regular employee out to pick up cash over $10,000. You're asking to get that person robbed. Earlier this month there was a courier here in Dallas shot and killed for the deposit he was couriering. He was armed and a trained constable for a county in Dallas and still didn't have a chance.

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#893141 - 01/24/08 07:37 PM Re: CTR and Mail Depsosit/Shipment??? Milby
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What if they don't know what's in the bag? Do I need to require the courier to ID & get the social of every customer they receive a bag from?

Oh I think I opened a can of worms.
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#893286 - 01/24/08 08:39 PM Re: CTR and Mail Depsosit/Shipment??? WonderWoman
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We provided this service for some of our best customers at another FI I worked for BUT we only picked up NON CASH deposits in clear sealed bags. If we ever found cash in a deposit, the service was immediately cancelled for that customer.

I suspect your bonding company would have a problem with a bank employee couriering cash. Ours certainly did, hence why we would not accept cash.

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#893372 - 01/24/08 09:40 PM Re: CTR and Mail Depsosit/Shipment???
WonderWoman Offline
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I just received confirmation from FinCEN regarding the proper completion of these types of situations (Courier bringing in more than $10,000 in cash from a customer).

We must list our employee’s (the courier’s) information in Section B on the CTR.

He said verifying the ID of the person who handed the courier the deposit is not correct.
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#893624 - 01/25/08 03:02 PM Re: CTR and Mail Depsosit/Shipment??? WonderWoman
BrendaC Offline
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Several of our banks offer courier services for deposits; however, no cash is permitted. We pick up checks only (and most of these are converting to remote capture.) As previously mentioned, you should have a discussion regarding this service with your bonding company.
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#893736 - 01/25/08 04:23 PM Re: CTR and Mail Depsosit/Shipment??? BrendaC
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OK - bonding issue aside ...

I have CTRs that are due & am conflicted as to what should go in Section B. I disagree with FinCEN's take on the situation - that it should be our employee's information ...

... but do I have a choice?
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#893782 - 01/25/08 04:51 PM Re: CTR and Mail Depsosit/Shipment??? WonderWoman
BrendaC Offline
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This is Treasury's rule and FinCEN is designated Treasury office with responsibilities for CTRs. While verbal guidance (even from FinCEN) is never 100% foolproof, I think you should go with it. I'm surprised though, I would have used ID of person providing bag to bank employee.
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#893798 - 01/25/08 05:01 PM Re: CTR and Mail Depsosit/Shipment??? BrendaC
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I like FinCEN's response. If a bank employee picks up a bag of cash from a money launderer, FinCEN wants to know the ID of the bank employee, but not the money launderer. Go figure.
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#893925 - 01/25/08 06:42 PM Re: CTR and Mail Depsosit/Shipment??? Retread
Milby Offline
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FinCEN once told us that they wanted the actual customer info, NOT the mobile branch employee/courier. Go figure...

Like BrendaC, we stopped allowing cash in the deposits.

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