Thread Options
|
#678813 - 02/02/07 07:52 PM
Re: CTR and Mail Depsosit/Shipment???
Rangers Fan
|
Power Poster
Joined: Jul 2006
Posts: 3,889
CA
|
I would put the Business in Section A and the courier's information in Section B. JMO
_________________________
He who sings scares away his woes. ~Cervantes
|
Return to Top
|
|
|
|
#678967 - 02/02/07 08:51 PM
Re: CTR and Mail Depsosit/Shipment???
Rangers Fan
|
10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
|
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)."
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
|
|
|
#679410 - 02/05/07 12:52 PM
Re: CTR and Mail Depsosit/Shipment???
Rangers Fan
|
10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
|
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.
_________________________
John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
|
Return to Top
|
|
|
|
#679598 - 02/05/07 03:58 PM
Re: CTR and Mail Depsosit/Shipment???
John Burnett
|
10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
|
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.
_________________________
John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
|
Return to Top
|
|
|
|
#705798 - 03/23/07 04:42 PM
Re: CTR and Mail Depsosit/Shipment???
Rangers Fan
|
Platinum Poster
Joined: Apr 2005
Posts: 684
Jersey Shore
|
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?
|
Return to Top
|
|
|
|
#705806 - 03/23/07 04:56 PM
Re: CTR and Mail Depsosit/Shipment???
Jerseygirl
|
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
|
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?
|
Return to Top
|
|
|
|
#705825 - 03/23/07 05:06 PM
Re: CTR and Mail Depsosit/Shipment???
devsfan
|
Platinum Poster
Joined: Apr 2005
Posts: 684
Jersey Shore
|
But what if it is a courier service not an armored car?
|
Return to Top
|
|
|
|
#893117 - 01/24/08 07:17 PM
Re: CTR and Mail Depsosit/Shipment???
Jerseygirl
|
Diamond Poster
Joined: Mar 2007
Posts: 2,108
gone fishin'
|
*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?
_________________________
My opinions are my own, and not that of my employer.
|
Return to Top
|
|
|
|
#893129 - 01/24/08 07:29 PM
Re: CTR and Mail Depsosit/Shipment???
WonderWoman
|
Platinum Poster
Joined: Apr 2007
Posts: 953
Tejas
|
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.
|
Return to Top
|
|
|
|
#893141 - 01/24/08 07:37 PM
Re: CTR and Mail Depsosit/Shipment???
Milby
|
Diamond Poster
Joined: Mar 2007
Posts: 2,108
gone fishin'
|
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.
_________________________
My opinions are my own, and not that of my employer.
|
Return to Top
|
|
|
|
#893286 - 01/24/08 08:39 PM
Re: CTR and Mail Depsosit/Shipment???
WonderWoman
|
Anonymous
Unregistered
|
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.
|
Return to Top
|
|
|
|
#893372 - 01/24/08 09:40 PM
Re: CTR and Mail Depsosit/Shipment???
|
Diamond Poster
Joined: Mar 2007
Posts: 2,108
gone fishin'
|
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.
_________________________
My opinions are my own, and not that of my employer.
|
Return to Top
|
|
|
|
#893624 - 01/25/08 03:02 PM
Re: CTR and Mail Depsosit/Shipment???
WonderWoman
|
Power Poster
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
|
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.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.
|
Return to Top
|
|
|
|
#893736 - 01/25/08 04:23 PM
Re: CTR and Mail Depsosit/Shipment???
BrendaC
|
Diamond Poster
Joined: Mar 2007
Posts: 2,108
gone fishin'
|
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?
_________________________
My opinions are my own, and not that of my employer.
|
Return to Top
|
|
|
|
#893782 - 01/25/08 04:51 PM
Re: CTR and Mail Depsosit/Shipment???
WonderWoman
|
Power Poster
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
|
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.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.
|
Return to Top
|
|
|
|
#893798 - 01/25/08 05:01 PM
Re: CTR and Mail Depsosit/Shipment???
BrendaC
|
Power Poster
Joined: Oct 2003
Posts: 2,548
Southeast
|
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.
_________________________
Politicians are like diapers. They need to be changed often and for the same reason.
|
Return to Top
|
|
|
|
#893925 - 01/25/08 06:42 PM
Re: CTR and Mail Depsosit/Shipment???
Retread
|
Platinum Poster
Joined: Apr 2007
Posts: 953
Tejas
|
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.
|
Return to Top
|
|
|
|
|
|