11/12/2007
We would like to run an ad in our newspaper with photos of money in it. I think we can do this, but I was under the impression that there is a size requirement. Am I correct? If so where can I find the size requirements?
11/05/2007
We have recently added several tellers to the foreign currency area of the money room. What are the "best practices" regarding operational controls over the inventory? Do tellers transfer stock back and forth with a head teller to process orders and incoming transfers or am I thinking too much in the box and trying to replicate ordinary practices from the commercial side of the money room?
10/22/2007
When a deposit slip is filled out the cash should be indicated on the deposit slip as cash. How important is this? We have tellers filling out the deposit slips with the total amount of cash as the total amount of the deposit. I know the BSA states "the slip or ticket shall record the amount of any currency involved". Does the amount of cash need to be in the line for currency and the deposit total line? Do the regulators really check this?
08/14/2006
Several years ago, I was informed by the BSA Compliance group of the IRS that when a bank opens a safe deposit box and discovers cash exceeding $10,000 inside a CTR should be prepared. I have changed jobs and do not have a copy of this consultation, can you advise?
08/14/2006
For the purposes of CTR reporting, does aggregation of multiple transactions include multiple entities? Example: we have an individual who owns three MSB entities, separate tax IDs, different names, and operates in three different towns. Should their cash transactions be aggregated? If so, who goes on Part A of the CTR, the owner and/or all three entities? Another scenario, a customer has a joint account, a corporate account, and is a signer on their child's account. If cash is deposited into all three accounts by one of the joint account holders, an employee of the corporation, and the child into each respective account. Which accounts would be included on a CTR and reported under who's name? If it makes a difference, if you do not know who made each of those three deposits should they be aggregated? Bottom line: how far does aggregation go?