A few months back, our core system added a single freeform 'note' line in the CTR function. It's there now, but we can choose to make input in the field required. It would be a very big help to us in BSA to have a consistent, disciplined way to have the tellers ask for source of funds or purpose of withdrawal while a transaction is happening, instead of everyone trying to remember later.

Does anyone else require such information at the teller line in this manner? What experiences did you have during implementation? I expect our branches would push back hard on having this added.

I don't understand why the push back if the field actually prompted the teller to ask the question that he or she is supposed to be asking (when needed for correct completion of the CTR). It's a reminder of something they ought to be doing.

Source of funds is not needed for the completion of the CTR. But it might influence our decision to file or not file a SAR if someone brings in $80,000.00 of cash.

Not a required field, but you should still be asking what the source of funds is for, for the exact reason you listed in your example.

Thread from a few years ago

If your contact personnel complain, remind them that they are being paid for their time, not their personal opinions.

We are on the cusp of "due diligence" being a legal requirement. All banks will be asking more questions. Set a dollar threshold where the question must be asked and indicate this is a "required" field. Train your personnel on "how" to ask the question. MYOB responses (or their equivalent) are helpful and should be noted.

I would love some suggestions on 'how' the front-line should ask the question, because I generally train them not to be coy (did you win the lottery??) in the hopes the customer will volunteer info, but polite and direct and just ask.

Ken, how do you recommend they phrase the question?

Not Ken, but we suggest tellers ask something along the following if you want to be direct:

Did you sell something?
Where did you get the funds? - we are required to ask this question

No use beating around the bush:

Could you please tell me the source of this cash?

I'm with you rlcarey. I find if they ask 'did you sell something' the customer may respond in a vague manner (something like that), or worse, just say 'yes' (and leaving that hanging out there) and then our front line is struggling with the follow up question.

If we are just going to be polite and direct, training is pretty simple.

or worse, just say 'yes' (and leaving that hanging out there) and then our front line is struggling with the follow up question.

"What did you sell?" is not a very hard follow up question... Not everyone is cut out to be in a customer contact position. It's all about having a conversation with the customer. However, I do agree with both of you - ask where the funds are from directly. It's much easier.

Randy's question listed above is exactly what we ask...

I concur. I'm serious though when I say the front line is flummoxed by follow up questions. Sometimes the customer says:
I cashed a check at XYZ Bank down the road (we get that one a lot, actually). How does everyone phrase that follow up question....or do you insert the word 'original' in your question, as in:

Could you please tell me the original source of this cash?

"The bank is concerned whenever an individual is carrying this much cash so I'm required to ask 1) where it came from or 2) what you are going to do with it." You'll have some tellers with greater verbal skills who can romance the answer, but if tact fails, that's their follow up. (I would ask about withdrawals only because they might be indicative of fraud in general or financial exploitation of the elderly specifically.)

To be fair to your contact personnel and increase the likelihood of a meaningful response, the form of the question needs to indicate it's not based on personal curiosity. Moreover, the people who might get complaints about your employees' impertinence need to back them up unequivocally.

Again, an MYOB answer is recordable and may yield more valuable information.