We have a business owner who will call in and authorize a withdrawal of cash over the phone and tell us an employee will be in to pick up the cash. We know the customer very well. The employees who pick up the cash are not authorized on the account, but we are having them sign on the withdrawal ticket for documentation of who picked up the cash. When we complete the CTR, do we put the information for the business owner in Section B, or the employee who comes in to pick up the cash? Thanks for your help!!!

You must put the conductor in Section B since he/she is the one leaving your bank with the cash, not the business owner. Naturally, this individual must give you complete ID including SSN. If you believe that the transaction is for the benefit of the business, it should be identified in Section A.

I would put the business as the benefactor and the employee picking up the money as the transactor.

I see this differently. IMO for this situation...the person who walks out the door with the cash conducted the transaction AND received benefit. Do you know what they are going to do with the cash when they walk out the door? What happens if he/she keeps it even though you think it will ultimately be given to someone else....do you have a guarantee that it will go to the person you think it will go to? No. I play it safe.....the person walking out the door benefits from the transaction at the point they left my bank....I have no way of knowing (and I dang sure won't guess) who may benefit at a later date.

In the case presented, the order for the cash withdrawal came from the business owner and the bank has knowledge that the owner is withdrawing cash for his business? Why would you ignore that?

Also, I hope that the business owner does not at some time make a claim that all of these transactions are fruadulent. Without his signature (or a taped record of the phone calls) the bank is taking a huge risk. Handing out over $10,000 in cash based on a verbal authorization would be an unacceptable risk at most institutions.

i agree with ricarey the bank is taking a major risk by doing this. you may want to look at setting some kind of limit - anything over $1,000 or what ever you fell this number should be must have an account owners signature.

We require our customers that do this to fax in a sheet with the denominations that they want and a signature on it. This way we can be sure to give the customer what they want, and at the same time we have verification that the business owner authorized the transaction.

Tex.Gal

we will do this as well!

How is a faxed signature proof of authorization? It would be worthless in court. Any one of his employees have access to his signature and could easily attach it to a facsilmile.

rlcarey,

we will do this only after we have talked to the customer on the phone and that customer has verifyed certain personal information on the account or if we have set a private password up for that customer and the customer must be a known to the bank.

If your attorney has blessed your process - I say go for it.

The "double tap" on verification is critical. I dealt with a bank last week that sent a wire based on faxed instructions from a customer. Letterhead was good. Signature was good. Nevertheless, the customer claimed no knowledge of the instruction or the beneficiary (foreign). Bank loses.

OK you guys have made your point i am going to look into changing our method on this one. i do agree with and always have agreed with the fact that thier is potental for losses on this topic, we are a small to mid size bank and sometimes you get hung on KYC to much and put to much trust on this issue. thanks for shining some light on this matter.