Armored car deposits-CTR

Posted By: Sunshine Banker

Armored car deposits-CTR - 07/25/12 08:52 PM

CTR-Our client hires an armored car service to deliver deposits to our financial institution for processing of deposits. It is my understanding we will need to obtain information regarding the person (the guard for armored car service) to supply information as the conductor of the transaction (when the threshold is met for CTR reporting purposes). Has anyone had to do this? Do you obtain Badge #, DL #, the ssn..., I did call the armored car service explained what and why needed. If they do not with to furnish, do we refuse delivery of deposit?
Posted By: rlcarey

Re: Armored car deposits-CTR - 07/25/12 08:57 PM

Here you have all the guidance there is:

http://www.fincen.gov/statutes_regs/guidance/html/fin-2009-r002.html

Whatever else you do is a risk based effort.

This horse has been beaten to death. If you wish to witness the beating, you might try a search on the subject smile
Posted By: Princess Romeo

Re: Armored car deposits-CTR - 07/26/12 05:38 AM

It's still a stupid ruling that only provides fodder for audits and examiners to nitpick. It does NOTHING to advance the efforts against money laundering. FinCEN needs to rethink this and come up with something that doesn't waste everyone's time.
Posted By: rlcarey

Re: Armored car deposits-CTR - 07/26/12 11:08 AM

Well said, and we have just passed the three year anniversary of this wonderful ruling. I guess it takes a long time to "re-think" something in the Federal government.
Posted By: Elwood P. Dowd

Re: Armored car deposits-CTR - 07/26/12 11:56 AM

Quote:
It's still a stupid ruling that only provides fodder for audits and examiners to nitpick.


If my auditor mentioned noncompliance as a criticism I would be looking for a new one based on their failure to pass a reality check. Have you actually seen it written up in examinations? I have not seen or heard of a regulatory agency pursuing the issue.

The ruling has sort of become "the emperor's new clothes" in BSA compliance; everyone complains about it as if it was real, but since the armored car companies have closed ranks and said they will not force their personnel to provide their identification, it is impossible for banks to comply. Regardless, some bankers continue to wring their hands and worry that some day...

The ruling is ridiculous and even with the new CTR, its forced aggregation on the armored car employee is counter productive to the interests of law enforcement. It should never have been published. We've seen FinCEN admit mistakes before; e.g. the sole proprietorship ruling, but they're still singing the company song on this one.


Posted By: C.A.L.

Re: Armored car deposits-CTR - 07/26/12 02:10 PM

I did have an FDIC examiner "mention" it to me last year. After we discussed it a little further she actually removed it from the recommendations. However, to avoid any further issues we now obtain as much information as the armored car employee will give us. They will typically give up only their name and badge # and that works for me. smile
Posted By: Sunshine Banker

Re: Armored car deposits-CTR - 07/26/12 03:25 PM

Thanks to everyone and their thoughts on this one, many of which I share.
Posted By: Compgal

Re: Armored car deposits-CTR - 07/26/12 06:08 PM

For those of you who have customer deposits picked up or orders delivered that are done on behalf of the bank through armored car services, what are you doing to identify armored guard information when the deposits can be picked-up by different guards and different routes all ending up at the armored car service location?
Posted By: rlcarey

Re: Armored car deposits-CTR - 07/26/12 06:23 PM

If the armored car is acting on behalf of the bank, are you not operating a mobile branch and the drivers, as agents of the bank, be gathering the information needed for any CTRs from the people handing them the deposits?
Posted By: Compgal

Re: Armored car deposits-CTR - 07/26/12 06:28 PM

As I understand the process, the client arranges the deposit pick-ups, pays or is charged throught the bank for the service, but the bank arranged the armored car service to process the deposits or deliver orders back to the client.
Posted By: Kathleen O. Blanchard

Re: Armored car deposits-CTR - 07/26/12 06:42 PM

Is the armored car contract with the bank or with the customer?
Posted By: Compgal

Re: Armored car deposits-CTR - 07/27/12 03:07 PM

The contracts are signed by the customer and pays the fee directly to the armored car service.
The Bank signs a "Service Agreement" with the armored car service in order for them to process the deposits or orders for our clients. The armored car then maintains inventory of currency which is set up as an additional cash vault supply of the Bank.
Posted By: John Burnett

Re: Armored car deposits-CTR - 07/27/12 03:42 PM

As I read it, that makes the carrier the agent of the customer, not the bank.
Posted By: Kathleen O. Blanchard

Re: Armored car deposits-CTR - 07/27/12 03:44 PM

That is how it looks to me, the customer has contracted for the service.
Posted By: Compgal

Re: Armored car deposits-CTR - 07/27/12 03:50 PM

So, is the armored guard information necessary for us to list on the CTRs?

Would a single CTR be completed for each business having reportable transactions or would this mean we have to aggregate all transactions to one CTR (listing each business) processed by the armored car service?
Posted By: John Burnett

Re: Armored car deposits-CTR - 07/27/12 03:58 PM

If the courier acting as a customer agent brings in 12 deposits with cash totaling over $10,000, you file a single CTR with 12 persons on whose behalf ... and one conductor (the warm body bringing in the deposits). Go up to the start of this thread for a discussion on what fun you might have obtaining the courier's information.
Posted By: Compgal

Re: Armored car deposits-CTR - 07/27/12 04:12 PM

The courier does not bring these deposits into the bank, so we have no way of getting ID from a guard. There are multiple deposit pick-ups from various businesses which are not on the same routes which means different guards would be picking up daily that end up at the armored location where that armored service location then processes the deposits for the bank.
Posted By: rlcarey

Re: Armored car deposits-CTR - 07/27/12 04:13 PM

So, who does the CTRs for these deposits?
Posted By: Compgal

Re: Armored car deposits-CTR - 07/27/12 05:02 PM

The armored car services provides a list of deposits received to the Bank. When one of the entities have a reportable amount, the Bank will complete the CTR listing the business and Section B is just checked as Armored Car.
Posted By: John Burnett

Re: Armored car deposits-CTR - 07/27/12 08:29 PM

So the armored car service is at both ends of the transaction -- agent for the customers in picking up the deposits and agent for the bank in accepting those deposits. Interesting.

I'm afraid to suggest how I think FinCEN might parse those facts to determine how the CTR should look.
Posted By: Kathleen O. Blanchard

Re: Armored car deposits-CTR - 12/05/12 09:05 PM

Originally Posted By: Ken_Pegasus
Quote:
It's still a stupid ruling that only provides fodder for audits and examiners to nitpick.


If my auditor mentioned noncompliance as a criticism I would be looking for a new one based on their failure to pass a reality check. Have you actually seen it written up in examinations? I have not seen or heard of a regulatory agency pursuing the issue.

The ruling has sort of become "the emperor's new clothes" in BSA compliance; everyone complains about it as if it was real, but since the armored car companies have closed ranks and said they will not force their personnel to provide their identification, it is impossible for banks to comply. Regardless, some bankers continue to wring their hands and worry that some day...

The ruling is ridiculous and even with the new CTR, its forced aggregation on the armored car employee is counter productive to the interests of law enforcement. It should never have been published. We've seen FinCEN admit mistakes before; e.g. the sole proprietorship ruling, but they're still singing the company song on this one.



Are banks continuing to either ignore or do the best that they can with the armored car issue and the new electronic CTR form?
Posted By: kw004h

Re: Armored car deposits-CTR - 06/25/14 05:56 PM

I'm reviving this old thread to tag on some questions. For anyone filing CTRs in the manner the OP described (customer contracts with armored car service, transaction is processed at armored car location, details sent to the bank for crediting customer's accounts and CTR aggregation/filing as necessary):

What name/location are you entering in Part III for the financial institution where transaction takes place? Are you using address of the location from where the CTRs are prepared and filed (so, perhaps, the main office, or administrative office?) even though the transactions did not occur there?
OR
Are you entering the address of the Vault, even though it's not a branch of the financial institution? (I tend to think this would be "less right" than the first.)

I couldn't find any guidance on this within the model CTRs completed as guidance, because it's not specific about where the currency is actually processed. If anyone has any insight, it would be much appreciated! Otherwise, I'll have to roll the dice and ask whoever's taking the calls at FinCEN today! :-) Thanks!
Posted By: Rudy06

Re: Armored car deposits-CTR - 05/14/15 01:07 PM

Did anyone ever find an answer to KW004h's question? Our bank is moving toward a similar process. My initial opinion is to use the address for the branch where the transaction is processed. Thank you.
Posted By: kw004h

Re: Armored car deposits-CTR - 05/15/15 05:04 PM

I did speak to someone at FinCEN, and got verbal recommendation. We were told to use the address of the location where the transactions was really processed (the vault location), even if it is not an official "Bank" location.

But, it was just verbal advice - If you call FinCEN with the same question, I'd be curious to know whay response you are given!
Posted By: PrimeTime

Re: Armored car deposits-CTR - 05/15/15 05:47 PM

And that's where very carefully written memos will save you. Document everything.
Posted By: Little Miss BSA

Re: Armored car deposits-CTR - 05/20/15 04:46 PM

One of our customer's just started using same service so if anyone has been successful with filing the CTRs for this type of service I would greatly appreciate some feedback. Otherwise I am just thinking of starting to exempt these customers to avoid these CTR's because every time we call FinCEN we get a different version with very different suggestions on how to complete the CTR. .
Posted By: RYK190

Re: Armored car deposits-CTR - 02/28/18 02:36 PM

Any recent guidance on handling "indirect" CTRs in a situation like this? For filing purpose, I'm leaning towards using the actual date the courier picked up the currency regardless if the branch is an official bank location. From my experience, the whole process usually takes more than 15 days, as it would be dependent upon the processing bank to credit the "home" bank with a notification. In such a situation, we do end up having a late CTR, which seems to be inevitable. Please advise.