A bank employee (not our courier) delivered over $10k in cash to a bank customer. Do we have to identify the bank employee personally or can we say Armored Car (FI)?
What method of identification do you use for a minor on a CTR?
Are savings account transactions considered exempt from CTR reporting for the business customer that is an exempt non-listed business? What about cash payments to a loan account?
From 31 CFR 1020.315: The exemptible accounts of a non-listed business or payroll customer include transaction accounts and money market deposit accounts.
From Federal Reserve Act 19(b)(1)(C): The term "transaction account" means a deposit or account on which the depositor or account holder is permitted to make withdrawals by negotiable or transferable instrument, payment orders of withdrawals, telephone transfers, or other similar items for the purpose of making payments or transfers to third persons or others. Such term includes demand deposits, negotiable order of withdrawal accounts, savings deposits subject to automatic transfers and share draft accounts.
We have a business account with approximately 8 authorized signers and a qualifying transaction from the night drop. On the CTR, I understand that the Night Drop explains why you have not identified a conductor, but do I list all the authorized signers on the account (all parties benefit from deposits) or just the business?
Based on the change to Texas law Sec. 506.001. CONCEALED HANDGUN LICENSE AS VALID PROOF OF IDENTIFICATION.
(a) A person may not deny the holder of a concealed handgun license issued under Subchapter H, Chapter 4l l, Government Code, access to goods, services, or facilities, except as provided by Section 52l.460,Transportation Code, or in regard to the operation of a motor vehicle, because the holder has, or presents, a concealed handgun license rather than a driver's license or other acceptable form of personal identification.
Does this mean that community banks must accept the concealed handgun license as a primary form of identification? Or can we use it as secondary to other identification and still be within the law?
Regarding CTR forms, what is the definition of "Shipment" on box 24c "Mail Deposit or Shipment." Looking for clarification of when this would be utilized?
While conducting our annual DOEP/CTR reviews we identify potential new customers that may qualify for exemption. We have one that is a non-profit corporation, a religious order, that has a DBA account that operates a private school. Their source of cash is donations they solicit for the operation of the school. They do an excellent job of fundraising and have enough transactions to qualify for exemption. I have been unable to find a definitive answer in guidance that this sort of non-profit operation qualifies as a "commercial enterprise" under the regulation. I found an old reference back in 2004 to a private school that would not be eligible for exemption, but nothing more recent and nothing specific in the updated guidance. Can this type of entity be considered for exemption? Thank you.
A business customer deposits $9,750.00 in cash to their checking account and then gives the teller $300.00 in bills to get coin. Is a CTR needed and if so do you report $10,050.00 as cash in and nothing in the cash out column or $300.00 in the cash out column?
What information is a bank employee allowed to give a customer regarding the CTR?
I am in the process of exempting a business as a Phase II Customer. It is a local grocery store that is a registered MSB (due to cashing checks over $1,000). Can an MSB be exempt under Phase II? I have been told by an examiner that yes they can, but then I have been told by a rep from FinCEN that no they can not. Also, if they can be exempt, what forms besides the BSA Exemption Review Form do I need to obtain? We only have one other Phase II Exemption who also provided their P&L's. This business, however, is not willing to provide this information. I have weighed out if it would just be easier to go ahead and continue filing CTR'son this business, but with at least 4 CTR's per week, it would be better to exempt.