We have 1 customer that hired an ACS to pick up their deposits to deliver to bank for processing. In the past we obtained the ACS's employees's name and badge number. We are descrete filers,just curious-has anyone started using the ACS's information vs the ACS's employees info -any problems filing?
Thank you.

We are discrete filers also and we immediately followed the FinCEN ruling examples with ACS company info and no problems so far.

Could you consider an exemption? For example, a grocery store hires an ACS to deliver their deposits to the bank and perform change orders as necessary.

The grocery store (assuming it's not eligible for exemption as a listed company) might qualify for an exemption under what used to be called "phase II rules." Change orders from the store's deposit account could be included under that exemption, but currency exchanges would not be.

Thanks to both for taking the time to share the information and suggestions.

Thank you.