Answer by John Burnett: FinCEN has not provided further information and, from what I understand, has no plans to do so. The interpretation that is causing all the commotion is a simple restatement of the standard CTR requirements. The fact that the industry moved away from the paradigm in which deposits were collected by the bank's armored car agent toward the paradigm in which depositing companies contract with the armored carrier changed the agency relationship.
Your bank has a choice. It can continue accepting deposits under the present arrangement and filing incomplete CTR information (sans the information that the armored car representatives refuse to provide); you can continue working on the armored car company to extract compliance from them; or you can make your problem your customer's problem and try to leverage that relationship to wring compliance out of someone.
Answer by Ken Golliher: Please call the Helpline and ask them what you are supposed to do in this circumstance. Then, write a memo to file regarding what they told you. Then, do it.
They have a stock answer that is pure improvisation on their part, but you need to get it directly from them.
First published on BankersOnline.com 4/9/12