Two Questions - One of Those Days

I'm developing a questionnaire for our customers who own and operate ATMs. I've plagiarized the exam procedures, but management has a "why" question that I simply can't answer as I don't question why, I just simply do what the FFIEC says. I've told management that I'll do my best to find out why, so here goes. Why does the FFIEC want us to determine the ISO's target geographic market? Management feels that question is implicitly answered by the location of the ATM(s).

My second question. We have a handful of small used car lots. We're in the middle of tax refund season. These used car dealers have significantly more cash and significantly more CTRs. I feel that I understand the activity and that it is not suspicious. However, as this is my first tax season as BSA Officer here is my question - is this typical? OR is this something that is unique to "small town USA" markets where people rush to the Bank to get cash after they get tax refunds and then rush out to buy used cars with that cash? I'm trying to get a feel for future planning purposes.

Thanks in advance.

1. My best guess (I could be wrong, so I'd wait for someone else to respond) is if your customer is an ISO, you want to ensure their market area... Are they targeting local customers, regional customers, domestic customers, or international customers.

2. You are not the only one who sees the increase in cash activity during tax season. This is my 3rd bank and all have experienced similar activity.

I also see around tax time an increase in cash activity by my customers and I have been doing this job since 2013. Usually the day the ACH deposit is put in, the cash is immediately taken out. What blows my mind is the amount of some of the refunds. I will never in my lifetime get as much back as I see from some of my customers.

Also see a lot of cash activity with our used car dealerships, so yes, people are cashing their IRS refund check and taking cash to buy cars.

Thank you both.

The "really" amazing thing to me is the size of the tax refunds given the average account balances and the average size of the ACH payroll deposits.

For the life of me, I just don't understand why people don't use checks. I wouldn't feel safe walking around with a gangster roll of cash.

Some people use their tax withholding as a "savings" account. They like getting the big refund and can't pull it out for stupid spending. Not a fan of giving Uncle Sam an interest free loan, but it works for some people.

Yes to your second question, from the New England region we see this annually.