Is the bank required to get the required information for non-account holders that purchase a monetary instrument under the $3,000? Example: I am a non-account holder and I come into the bank with $2,000 cash and the bank sells me a cashier check. Is the bank required to get:
•If the purchaser does not have a deposit account with the bank:
â—¦Name and address of the purchaser.
â—¦Social Security or alien identification number of the purchaser.
â—¦Date of birth of the purchaser.
â—¦Date of purchase.
â—¦Types of instruments purchased.
â—¦Serial numbers of each of the instruments purchased.
â—¦Dollar amounts of each of the instruments purchased.
◦Specific identifying information for verifying the purchaser’s identity (e.g., state of issuance and number on driver’s license).

OR is this only required for transactions for $3,000 and over?

The BSA recordkeeping requirements for the purchase and sale of monetary instruments applies to purchases (including multiple purchases that aggregate) between $3,000 and $10,000 inclusive. Institutions with multiple branches may voluntarily choose to collect this information for lower dollar amounts in the event that a single purchase makes multiple purchases in the same business day.

Although the regulation does not require recordkeeping in the scenario described, the institution's bank specific policy and procedures may exceed the regulatory requirements.

Another thought, why provide these services to non-customers? I guess if you change a significant fee it might be worth it.

Brian is correct, but I'll offer a sidebar.

The records banks are required to keep in connection with monetary instrument sales for cash are completely, totally worthless; they serve no law enforcement purpose whatsoever.

They were intended to be cumbersome enough to dissuade banks from selling checks to non customers for cash. It took awhile, but most banks eventually heard the message. Some of those with a hearing loss only figured it out when they realized the practice required a manual 314(a) search.

Banks that still do it, even below the $3,000 threshold, missed the crescendo...

I have bank examiners on site asking for the required information for non customers that purchased monetary instruments. (I am new to the bank and I know the falls of selling to non customers, that is another story). The examiners are not asking for the $3,000 to $10,000 monetary instrument log. They are asking the bank to prove that we collect that information for all non customers that purchase monetary instruments. I was always under the impression that the rule applied to the 3 to 10 thousand log, not to all non customers.

It does - ask them for a citation.

Yup.

Any requirements or restrictions on instruments involving less than $3,000 would have to be self imposed. If you are the "new guy," read the bank's policies and procedures before you wade into something. If you say you will do it there, it's the equivalent of the law within the 4 walls of your institution.

We get citations with a simple "look it up in the FFIEC" manual or simply " it is a IIA standard violation" without detail.

I've trained for the FDIC and the OTS (RIP). With both agencies, the internally published protocol was: If the banker asks for a citation to authority you are required to provide it.

It's a reasonable request and, if the assertion is going to make it's way into the written report, one they will be required to offer there.